The DEIS in Plain English

The 2001 Roadless Rule (66 FR 3244, 36 CFR Subpart B (2001)) "prohibits road construction, road reconstruction, and timber harvesting in inventoried roadless areas, with limited exceptions." It grew out of a 1999 directive from President Clinton to "provide appropriate long-term protection for most or all of these currently inventoried 'roadless' areas," following the Wilderness Act of 1964 and two national inventories (RARE I in 1973, RARE II in 1977). The rule identifies nine features that often characterize these areas, including high-quality soil, water, and air; sources of public drinking water; habitat for threatened and endangered species; primitive recreation opportunities; and traditional cultural properties and sacred sites. Limited exceptions exist for things like public health and safety, mineral leases, and small-scale "stewardship" tree cutting, which the rule's own text says is "expected to be infrequent."

Rescinding the rule "is intended to return decision-making for these activities to local officials, in conjunction with forest-level land management planning." The document is explicit that "this proposed rescission does not mandate timber cutting or road construction but would relieve regulatory burden relative to management of National Forest System lands." Under the current 2001 Rule — described in the DEIS as the "no action" alternative — the national prohibitions stay in place.

The 2001 Rule "applies to approximately 44.7 million acres of National Forest System lands, including in Alaska." Roadless areas overall total about 58.2 million acres (originally reported as 58.5 million acres, or 31 percent of National Forest System lands, before "mapping modernization and technical corrections"). The 44.7-million-acre figure excludes about 9 million acres of Idaho Roadless Areas and 4 million acres of Colorado Roadless Areas, which are governed by their own state-specific rules and are not affected by this rulemaking. More than 95 percent of the remaining inventoried roadless acreage sits in ten Western states, led by Alaska, Montana, and California.

The rule "has been the subject of nine lawsuits" in federal courts across Idaho, Utah, North Dakota, Wyoming, Alaska, and Washington, D.C., and "was both enjoined and reinstated multiple times." In 2005, under the Bush Administration, USDA replaced it with a State Petitions Rule allowing governors to seek state-specific arrangements; a federal court set that rule aside in 2006 and the Ninth Circuit affirmed in California ex rel. Lockyer v. U.S. Department of Agriculture, 575 F.3d 999 (9th Cir. 2009). Idaho and Colorado ultimately secured their own state-specific roadless rules, which remain in effect today and replaced the 2001 Rule in those states.

The Tongass National Forest contains 9.3 million acres of inventoried roadless area, "about 56 percent of the Forest." A 2020 rule fully exempted the Tongass from the 2001 Roadless Rule; that exemption was repealed in 2023; and now Executive Order 14153, "Unleashing Alaska's Extraordinary Resource Potential," directs the Secretary of Agriculture to "reinstate the 2020 Alaska Roadless Rule." The DEIS states that its analysis "relies on and incorporates by reference" the 2020 Final EIS for that rule rather than building a fresh Tongass-specific analysis for this rulemaking.

The stated purpose is "to reduce regulatory burden and return land management decision-making for inventoried roadless areas to local Forest Service officials." The DEIS argues that a "single, national blanket approach... constrains responsible officials from exercising the timely, place-based discretion needed to meet the Forest Service's multiple-use mission," and that the rule "limited the Forest Service's ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns."

The rule's exceptions were meant to be used infrequently, and in practice "regional forester approval of exceptions under the 2001 Roadless Rule has been limited," with about 188 documented exception proposals recorded between 2018 and 2025. Actual activity data shows "an average of 500 acres per year of timber harvest and a total of 1.8 million acres of hazardous fuels reduction within IRAs" over the past decade, and "best available records" indicate roughly 60 miles of new permanent roads built in roadless areas since 2013.

The rulemaking is framed as advancing several 2025 executive orders. It states that "this deregulatory action advances the policy objectives of Executive Order 14192, Unleashing Prosperity Through Deregulation." It quotes Executive Order 14225, Immediate Expansion of American Timber Production, declaring that "the United States has an abundance of timber resources that are more than adequate to meet our domestic timber production needs, but heavy-handed Federal policies have prevented full utilization of these resources." It also cites Executive Order 14154, Unleashing American Energy, and Executive Order 14153, Unleashing Alaska's Extraordinary Resource Potential, which directs reinstating the Tongass exemption.

Secretary Brooke L. Rollins "publicly announced the intent to rescind the 2001 Roadless Rule" on June 23, 2025. A Notice of Intent published August 29, 2025 opened a 21-day comment period, during which "over 220,000 comment letters were received," representing "over 625,000 submissions" when petition signatures are counted individually. Of those, "approximately 99 percent were generally opposed to the proposed rule recission, while approximately 1 percent were generally in support." The DEIS states that comments not incorporated were rejected because the underlying concern was "already accounted for, outside the scope of the rulemaking and purpose and need, and/or outside the authority of the Department or agency."

The Forest Service notified Tribes and Alaska Native Corporations of the opportunity to consult in July 2025 and held a Tribal forum engagement session on August 5, 2025. "The Forest Service received 64 requests for consultation, 29 consultations have been held, and an additional 5 scheduled."

A Final Rule and Final Environmental Impact Statement "are anticipated to be completed in 2027." An additional opportunity to comment will follow publication of the proposed rule in the Federal Register, submitted electronically through regulations.gov (docket FS-2025-0001) or by mail.

The agency's land management planning framework can address the same conservation goals the 2001 Rule was meant to address — ecological integrity, drinking water, wildlife diversity, recreation, scenic character, cultural resources — while allowing "place-based, collaborative decision-making" instead of a "one-size-fits-all national mandate." It states that "conditions across National Forest System lands have changed substantially" since 2001, especially in the West, with more drought, extreme temperatures, wildfire, and insect and disease outbreaks, and that this, combined with "evolving Department priorities for active forest management and deregulation," diminishes the basis for a national prohibition. The Secretary's authority to manage the National Forest System comes from the Organic Administration Act of 1897 and the Multiple-Use Sustained-Yield Act of 1960, and the DEIS frames this rulemaking as the same kind of discretionary exercise that created the 2001 Rule in the first place.

Alternative 1 continues the 2001 Roadless Area Conservation Rule unchanged. It prohibits road construction, reconstruction, and timber harvest in inventoried roadless areas (IRAs), with limited exceptions — for public health and safety, reserved rights, existing mineral leases, road realignment to prevent damage, and stewardship purposes. It applies to 44.7 million acres nationwide, including 9.3 million acres on the Tongass National Forest in Alaska. Changing an IRA boundary would require a new rulemaking, though the Chief can approve small technical corrections. The DEIS treats this alternative as the "environmental baseline" — the benchmark every other alternative's impacts are measured against.

Alternative 2 rescinds the 2001 Roadless Rule "in its entirety." It eliminates the nationwide prohibitions on road construction and timber harvest, removes the IRA designation from all 44.7 million acres (including the 9.3 million on the Tongass), and returns management of those lands entirely to each forest's existing land management plan. It would not change the separate state-specific Idaho and Colorado Roadless Rules. The DEIS is explicit that Alternative 2 "would not authorize any specific ground-disturbing projects" by itself — it changes what's legally possible, not what's immediately built.

Alternative 3 removes roadless protections and designation from 31.7 million acres: 4.5 million acres of non-National-Forest-System land and congressionally designated areas, 17.9 million acres near existing roads or within the wildland-urban interface (WUI — the zone between developed communities and undeveloped land) outside the Tongass, and the 9.3 million Tongass acres. The remaining roughly 13 million acres, all outside the Tongass, keep the same 2001-style prohibitions and exceptions as Alternative 1. It also adds a new process letting local officials propose boundary modifications to the Chief, with a minimum 30-day public comment period, plus a separate administrative-correction process for mapping errors. The DEIS frames this as responsive to comments wanting more local flexibility near roads and in fire-prone WUI areas while preserving "core or 'high value'" roadless land.

The 17.9-million-acre removal figure for Alternative 3 is broken into 5.1 million acres within the WUI, 6.3 million acres of "roaded roadless" area (within half a mile of an existing road), and 4.7 million acres that are both; it adds that "the remaining acreage was removed as the small, isolated areas did not meet previous mapping criteria."

The regulatory text for Alternative 3 (Appendix 2, § 294.14(g)) lets responsible officials, working with local governments, Tribes, and other parties, "propose boundary modification to the Chief" to correspond with "geographic features, land management plan management areas, or for other reasons," approved by the Chief with a minimum 30-day public notice period, or through a separate administrative-correction process for clerical or mapping fixes.

Under Alternative 2, about 4.8 million acres — 16 percent of forested land in the potentially affected IRAs — sit in areas current land management plans already allow for timber harvest and rate as more likely to be "operable"; Alternative 3 is "slightly less" at 4.3 million acres. These areas could contribute a 4 to 10 percent increase in total nationwide sawtimber harvest. Roughly 9,500 miles of road already exist within the potentially affected IRAs (2.5 percent of the whole National Forest System road network), and current plans would allow or generally allow new road construction on about 18 million acres (45.5 percent) under Alternative 2 and 14 million acres (53 percent) under Alternative 3.

Substantial acreage within the potentially affected IRAs carries a relatively high likelihood of burning under high-intensity, hard-to-manage conditions, and Alternatives 2 and 3 would allow more hazardous-fuel treatment in priority firesheds, with some strategically placed new roads potentially offering "fire control benefits." The same discussion also states that "the number, frequency, and density of wildfire ignitions are currently lower in designated wilderness and potentially affected IRAs compared to other NFS lands," and that more public road access under Alternatives 2 and 3 could increase human-caused ignitions.

Across biodiversity, cultural and historic resources, recreation and scenery, and Tribal rights and interests, the DEIS's comparison table consistently rates potential effects as least under Alternative 1, most frequent and broadest in scale under Alternative 2, and reduced — but still present — under Alternative 3 (for example, Alternative 3 "has similar effects to Alternative 2 but affects fewer acres" for recreation and scenery). On endangered species, a preliminary draft biological assessment found the proposed action "may affect, and is likely to adversely affect" 327 ESA-listed species and 71 critical habitats, with effects "similar or reduced" under Alternative 3.

The agency considered but did not analyze in detail several other approaches: a different way of drawing the wildland-urban interface boundary (a census-based method from Radeloff et al. 2023), which a sensitivity analysis found would produce about a 12 percent difference in remaining IRA acreage compared to the method actually used for Alternative 3; an alternative that would have kept existing IRA boundaries and permanent-road prohibitions while allowing temporary roads and timber harvest, eliminated as "not being responsive to the purpose and need"; and legislative options such as codifying the 2001 Rule or designating roadless areas as wilderness, ruled outside the scope of a rulemaking. State-specific rulemaking, similar to Idaho's and Colorado's, was not analyzed separately because states and Tribes can already petition for such rules under existing law regardless of what this rulemaking decides.

In 2001, the Roadless Area Conservation Rule "established a single, nationwide set of prohibitions intended to provide lasting protection for inventoried roadless areas within the National Forest System in the context of multiple-use management." The Rule identified nine features that "often characterize or are present within" IRAs: high quality or undisturbed soil, water, and air; sources of public drinking water; diversity of plant and animal communities; habitat for threatened, endangered, and sensitive species (and species that depend on large, undisturbed areas); primitive and semi-primitive recreation settings; reference landscapes; natural-appearing landscapes with high scenic quality; traditional cultural properties and sacred sites; and other locally identified unique characteristics.

In different places, the document states that the 2001 Roadless Rule "prohibited road construction, road reconstruction, and timber harvesting on inventoried roadless areas (IRAs) on 58.5 million acres, or 31 percent, of National Forest System lands"; that "roadless areas total approximately 58.2 million acres, or about 30 percent of all National Forest System lands"; and, in the section describing the currently affected environment, that "there are 44.7 million acres of IRAs subject to the 2001 Roadless Rule."

"More than 95 percent of IRAs managed under the 2001 Roadless Rule (outside of Colorado and Idaho) are in ten Western states," listed largest to smallest: Alaska, Montana, California, Utah, Wyoming, Nevada, Washington, Oregon, New Mexico, and Arizona. "In the West, IRAs were typically 5,000 acres or greater."

"The Forest Service manages approximately 22 million acres of Federal lands in Alaska, which are distributed across two national forests — the Tongass and Chugach National Forests, including over 14 million acres of inventoried roadless areas (9.3 million acres on the Tongass National Forest alone)." Elsewhere the document states that "Within the Tongass National Forest 9.3 million acres of inventoried roadless area [are] managed under the 2001 Roadless Rule, or about 56 percent of the Forest."

"Review of the geospatial data found that 44.3 million acres of these [the 44.7 million] are on National Forest System lands, meaning about 0.4 million acres of lands have had land ownership change since the 2001 Roadless Rule or there may be vertical integration problems (mapping errors) between the inventoried roadless data and official land ownership boundary data." A footnote explains that such misalignments "can amount to tens or hundreds of acres or more, especially because of the large area under analysis."

"Over 4 million acres are within Congressionally-designated wilderness, wilderness study areas, and wild segments of wild and scenic rivers" — specifically about 1.3 million acres (2.8 percent) in the National Wilderness Preservation System, 2.8 million acres of wilderness study areas, and 85,000 acres of wild river segments. The document states these "statutory designations have more restrictive and more permanent mandates than the 2001 Roadless Rule," so management changes there are "highly unlikely and not reasonably foreseeable," and for that reason these 4 million acres are excluded from the "potentially affected environment" analyzed in the rest of the document.

The "Idaho Roadless Rule (36 CFR 294, Subpart C) applies to approximately 9 million acres of Idaho Roadless Areas," and the "Colorado Roadless Rule (36 CFR 294, Subpart D) applies to approximately 4 million acres of Colorado Roadless Areas," including "upper tier protection on 1.2 million acres" that is "more restrictive" than the standard rule. The 44.7-million-acre national IRA figure used elsewhere in this section is explicitly the total "not including Co or ID."

Within the potentially affected IRAs, current land management plan components "further restrict (do not allow or generally do not allow) road construction on 21.8 million acres (54.5 percent of the potentially affected IRAs)" and "further restrict... timber harvest on 26.7 million acres (66.5 percent of the potentially affected IRAs)." The document notes "there is much variation between individual land management plans and Regions reflecting differences in local conditions, age of the plans, and changes in planning policies over time," and gives example plan language from forests including the Custer-Gallatin, Santa Fe, Ashley, Colville, and Nantahala and Pisgah, some of which describe IRAs as providing "biological strongholds for populations of threatened and endangered species" or committing to retain "undeveloped character."

"There are currently about 9,500 miles of roads within the potentially affected IRAs (9,400 miles of NFS roads, 100 miles of private roads) representing about 2.5 percent of the NFS transportation system," and "best available records of permanent road construction indicate that approximately 60 miles of roads were built within inventoried roadless areas after 2013." Historically, "an average of 500 acres per year of timber harvest and a total of 1.8 million acres of hazardous fuels reduction" occurred within IRAs under the 2001 Rule, with "more than half" of the fuels reduction credited to wildfire use and "an additional 25 percent" to prescribed burning. Separately, the document describes "about 188 documented proposals," roughly 10 percent involving road-related activity and 96 percent involving tree cutting.

The affected environment is further broken down by "potential timber harvest operability" — a nationwide geospatial estimate based on slope, distance from roads, and site productivity. "Likely Operable" areas are within 0.5 miles of a road, on slopes under 40 percent, productive for restocking, and free of statutory restriction. "Likely Operable but Complex" areas are similar but on steeper or more distant terrain. "Likely Not Operable" areas are more than a mile from a road, on slopes over 70 percent, unproductive, or subject to statutory restriction. The document specifies this operability estimate "is for analysis purposes only," and that "actual feasibility and need for timber harvest would be determined locally."

The National Forest System (NFS) road network peaked at 386,000 miles in 2000 and has since declined by 18,000 miles over the last 23 years, to roughly 368,000 miles today. The Forest Service attributes the decline to "increased emphasis on transportation system management, consideration for ecosystem protection and wildlife habitat connectivity, funding available for decommissioning unneeded roads, and recognition of declining funding for maintaining the road system." Two policies drove this: the 1999 Roads Analysis Policy and the 2005 Travel Management Rule (36 CFR Part 212), which required each forest to identify the "minimum road system" needed for safe travel and administration. Of the current network, about 65,000 miles (18 percent) are managed for standard passenger cars, 200,000 miles (54 percent) for high-clearance vehicles only, and 103,000 miles (28 percent) are "in storage" — temporarily closed to standard vehicle use.

NFS roads are classified into five maintenance levels, from Level 1 (roads in storage, receiving only basic custodial upkeep to prevent resource damage) through Level 2 (high-clearance vehicles only, no driver-comfort standards) to Levels 3 through 5 (maintained for standard passenger cars, with increasing comfort and traffic-control standards). Passenger-car roads break down into roughly 9,500 miles of pavement, 36,500 miles of gravel, and 19,000 miles of native (dirt) surface. Citing the 2024 Roads Program Fact Sheet, the DEIS states that "less than 10 percent of paved roads and less than 30 percent of gravel roads are in good condition."

A fiscal year 2023 Service-wide Asset Summary put the current replacement value of NFS roads and bridges at $39 billion. Using "the industry standard 4 percent of current replacement value" to estimate annual upkeep needs, the DEIS calculates a $1.6 billion annual maintenance need — but the Forest Service received only about $270 million in fiscal year 2023, "less than 20 percent of the estimated funding needed." In fiscal year 2024, appropriations were $73 million, with another $197 million coming from the Great American Outdoors Act, the Legacy Road and Trail Remediation Program (funded through the Infrastructure Investment and Jobs Act), and the Federal Lands Transportation Program — sources the DEIS itself flags as "outside of typical annual appropriations and not guaranteed." GAOA expired at the end of fiscal year 2025, and the IIJA funding is set to expire September 30, 2026. Annual road appropriations have fallen from a peak of $234 million in 2004 to $73 million in 2024, a decline the DEIS describes as "almost 70 percent." About 31,000 miles — 8 percent of the whole system, or 12 percent of open road mileage — were maintained, improved, or reconstructed in fiscal year 2024.

In 2024, the Forest Service estimated a deferred maintenance backlog of $6.9 billion for roads and bridges — but this figure is "based on passenger car roads only (maintenance levels 3 - 5)." In 2001, the estimated backlog was $8.4 billion "for all maintenance levels of roads." The DEIS explains the difference in method: in 2001 the agency had resources to survey 100 percent of NFS roads, while today it uses "a random sample method for determining deferred maintenance at a national scale," covering only passenger car roads, because "there is no current tracking mechanism" for Level 1 and 2 roads — which together make up roughly 82 percent of the entire road network by mileage.

Based on an informal agency survey, new NFS road construction in the lower 48 states costs $80,000 to $100,000 per mile for native (dirt) surface; adding gravel costs another $300,000 to $500,000 per lane mile; and asphalt paving costs roughly $1,000,000 to $2,000,000 per lane mile. In Alaska (Forest Service Region 10), costs run "four to five times" higher. These figures "do not include significant drainage structures such as bridges, retaining walls, or other substantial slope stabilization measures." Annual road maintenance costs $5,000 to $50,000 per mile, and decommissioning ranges from about $2,000 per mile for simple treatments (blocking entrances, installing water bars) to more than $50,000 per mile for complex treatments like removing culverts and restoring drainages.

For roads within IRAs specifically, the DEIS states that construction costs "are more likely to be much greater than typical road construction because of steep and difficult terrain, extensive earthwork, geotechnical challenges, costly infrastructure such as bridges or tunnels, and accessibility due to isolated locale," and concludes "it is not feasible to provide a typical cost per mile for road construction within the inventoried roadless areas." It cites the Federal Highway Administration's description of mountainous terrain (slopes frequently over 33 percent) as being of "unique difficulty and expense," and notes "some data sources indicate construction costs in mountainous terrain can be 3 to 10 times more per mile than flat terrain."

The 2001 Roadless Rule EIS found approximately 9,660 miles of existing roads within all IRAs at that time (including Idaho and Colorado). Today, the DEIS puts existing roads within the potentially affected IRAs (excluding Idaho and Colorado, which have their own state-specific rules) at approximately 9,500 miles — 9,400 miles of NFS roads and 100 miles of private roads — equal to about 2.5 percent of the entire NFS road system. Of that mileage, roughly 8,100 miles are native surface, 1,200 miles aggregate, and 100 miles asphalt; about 2,300 miles are in storage, 6,100 miles are high-clearance only, and 1,000 miles serve passenger cars. "There are no prohibitions or limitations on road maintenance for existing roads within inventoried roadless areas," and that maintenance work "is ongoing and would continue" regardless of which alternative is chosen. Separately, the DEIS states that "best available records" show approximately 60 miles of new roads were built within IRAs after 2013.

Independent of the Roadless Rule, individual forests' land management plans separately restrict road construction. For the Alternative 2 potentially affected environment, plans allow or generally allow road construction on 44.5 percent of the land (31.2 percent "generally allowed" plus 14.3 percent "allowed"), while construction is not allowed or generally not allowed on the other 54.5 percent. For Alternative 3, plans allow or generally allow construction on roughly half to just over half of that alternative's smaller affected environment, depending on which figure in the document is used (52 percent in the alternatives-effects discussion, 53 percent in the conclusion).

Under continued management pursuant to the 2001 Roadless Rule, road construction and reconstruction would remain prohibited "with limited exceptions." Since 2018, regional foresters have reviewed and approved 20 exceptions for road-related activity — covering resource protection, road realignment, road safety, reserved or outstanding rights, and one case tied to a Secretary of Agriculture determination on a Federal Highway reroute. The DEIS states that "an increase in NFS transportation system network miles under alternative 1 would be less likely than under alternatives 2 and 3," while cautioning that the last decade's low level of exception-based construction "is not a reliable predictor of future road construction or reconstruction." A deferred-maintenance increase is described as "inconsequential at the national scale," and a major impact on system-wide management costs is "less likely" than under the other alternatives.

Eliminating the 2001 Rule's national prohibitions "could result in new road construction and an increase of NFS transportation system mileage overall." Temporary road construction would be "more likely" on the 11.3 million acres (28.3 percent of the affected environment) within half a mile of existing roads, though permanent construction there is "less likely." Beyond that half-mile buffer, permanent road access "would be more likely." In the short term, any new permanent roads would be confined to the 18.2 million acres (45.5 percent) where land management plans currently allow construction. The DEIS calls a "measurable increase" in reported deferred maintenance "more likely" than under the other alternatives, and says it is "more likely that there would be an impact to overall transportation system management costs and maintenance fund redistribution" than under Alternatives 1 or 3 — while also noting that "budget and resource constraints could limit potential of new permanent road construction."

Like Alternative 2, removing prohibitions within half a mile of existing roads would more likely lead to temporary road construction there, while permanent construction stays less likely in that zone and would not likely produce "substantial growth in transportation network mileage overall." Permanent construction is described as "more likely" in wildland-urban interface areas beyond that half-mile buffer. Short-term permanent construction would be confined to the 14.2 million acres where land management plans currently allow it. Critically, on the roughly 13 million acres of the affected environment where the 2001 Roadless Rule's management would continue under this alternative, "effects would be similar to alternative 1" — construction only by exception, and "less likely." The DEIS calls a deferred-maintenance increase "more likely" than Alternative 1 but says it "would be less increase than alternative 2," because prohibitions remain in place across part of the affected area. Management-cost impact is similarly framed as "less likely" than Alternative 2's.

A summary table ranks all three alternatives across five measures — permanent road construction, temporary road construction, NFS road mileage increase, deferred maintenance increase, and management cost increase — with Alternative 1 "less likely" on every measure, Alternative 2 "more likely" on every measure, and Alternative 3 in between ("more likely but less than alternative 2," with permanent construction "much less likely" on the 13 million acres remaining under current management). The DEIS's conclusion states that under Alternatives 2 and 3, "roads would be constructed or reconstructed only where there is a need and funding source," with timber harvest and other active vegetation management generating "the greatest need," and that in the long term, "there could be some need to shift resources and funding from one region to another" as more permanent mileage is added.

The Forest Service authorizes over 200 different types of special uses on National Forest System land — water transmission, utilities, communications, agriculture, pipelines, recreation events, ski areas, and road access among them — processing roughly 4,000 new authorizations a year nationwide, including renewals. Authorizations are issued only after screening against 36 CFR 251.54, including land management plan consistency and environmental analysis. Terms range from a single day (a bike race) to no stated expiration (a county road easement). All the alternatives allow existing special use authorizations in roadless areas to continue, be reissued, or be renewed.

National forest boundaries contain parcels owned by states, private individuals, and other entities — "inholdings." Most existing and anticipated special uses "are either located or reasonably likely to be located where roads currently exist," because access to these inholdings typically depends on roads. Building those roads is usually the responsibility of the benefiting landowner, though the Forest Service may share responsibility for operation and maintenance "when it is in the interest of the Forest Service." The public can use open, unrestricted Forest Service roads without a permit, but road maintenance or commercial hauling typically requires one.

Under the Alaska National Interest Lands Conservation Act (ANILCA), Section 1323, and 36 CFR 251.110 subpart D, "the authorized officer must provide access adequate for the landowner's reasonable use and enjoyment" of non-federal inholdings. The document is explicit that this access "need not be the most direct or convenient and may be non-motorized or via alternate routes, including across other ownerships," and that if a landowner has an adequate alternative route, "the Forest Service is not obligated to authorize roaded access." Reasonable access is decided case-by-case and "may not require year-round motorized access via a road." The Forest Service recognizes ANILCA access as a statutory right, and the DEIS states there is "little difference in effect between alternatives" in how ANILCA requests would be handled.

The document states plainly that the 2001 Roadless Rule's prohibition on road construction "did not affect already existing access, occupancy, and use rights" — rights that exist by law, treaty, or other authority. These include rights to reasonable access across NFS lands to private property, mining claims for locatable minerals under the 1872 Mining Law, and land uses protected by Native American treaty rights, among others. The DEIS says "the reasonable exercise of reserved or outstanding rights for access, occupancy, and use of NFS lands within roadless areas would not be affected" under any of the alternatives.

Revised Statute 2477 allowed rights-of-way for public highways built across public domain land in the late 1800s and early 1900s, before the land became national forest. Congress repealed R.S. 2477 in 1976, but rights-of-way that predate a forest's establishment remain in effect unless relinquished, and the Forest Service "recognizes valid R.S. 2477 right-of-way as outstanding rights." The DEIS states there is "little to no effect between alternatives with respect to how the Forest Service would respond to an R.S. 2477 claim."

Under No Action (Alternative 1), "most new proposals involving road construction or timber harvest... that are not based on a reserved or outstanding right or provided in statute or treaty within IRAs would typically be rejected in the screening process" simply because the use conflicts with the roadless designation. Under the Proposed Action (Alternative 2), the DEIS anticipates "an increase in new proposals for uses that benefit the public or provide access to non-Federal lands within or adjacent to IRAs," including requests to expand existing access (more routes, better road quality, more frequent use), because new proposals "would be evaluated on their own merits and no longer be rejected outright due to prohibitions for road construction or reconstruction." Alternative 2 would also let the agency and the Federal Highway Administration "more swiftly accommodate public access needs involving road construction or reconstruction on highways" in affected IRAs. The Modified Rule (Alternative 3) would behave like Alternative 1 in areas that keep roadless protections and like Alternative 2 in areas where they're lifted.

The document cites specific figures for the scale of special-use activity: over 24,000 active Recreation Special Use permits generating about $150 million in fee revenue in fiscal year 2024, 127 ski area special use permits nationally attracting roughly 26 million visitors in FY2024, 15 of those 127 ski areas in or adjacent to inventoried roadless areas, and about 70 developed recreation sites (resorts, campgrounds, and similar, not counting ski areas) operated by permittees within roadless areas.

In discussing the Tongass National Forest, the document states that a decision "signed in November 2024... authorized mine expansion in an inventoried roadless area" (the Greens Creek North Extension Project), and characterizes it as consistent with a 2020 FEIS finding that "mining activities are expected to expand at existing sites, including Greens Creek on Admiralty Island." Elsewhere, the document also asserts that "roadless management on the Tongass National Forest has been consistent with the 2001 Roadless Rule for over a decade."

In its discussion of consultation and coordination requirements, the document states: "No Federal permits, licenses, or other authorizations must be obtained to implement the proposed action."

Minerals on National Forest System land fall into legal categories that determine what the Forest Service can and cannot do about them. "Locatable" minerals — gold, silver, copper, lead, zinc, barite, gypsum, and most "critical minerals" — are governed by the General Mining Law of 1872. That law "provides United States citizens a right to prospect, explore and develop these minerals on public domain lands," including "access suitable for conducting these activities," and "the Forest Service cannot prohibit reasonably necessary activities required for the exploration, prospecting, or development of valuable mineral deposits." The agency's role is limited to regulating locatable operations "to prevent or minimize damage to surface resources" under 36 CFR Part 228, Subpart A. "Leasable" minerals — oil, gas, oil shale, coal, gilsonite, geothermal, phosphate, and others — work differently: leasing is "discretionary," controlled by the Bureau of Land Management, and "most leasable mineral resources... may only be leased if the Forest Service provides consent."

Oil and gas leasing is governed by the Mineral Leasing Act of 1920 and the 1987 Federal Onshore Oil and Gas Leasing Reform Act. BLM issues the leases and approves drilling permits; the Forest Service "provides consent to the Bureau of Land Management to lease" and separately approves the site-specific "surface use plan of operations," then "monitors surface disturbing activities, enforces surface use requirements, and ensures reclamation." Coal leasing works similarly under the Mineral Leasing Act and the 1976 Federal Coal Leasing Amendments Act: BLM asks the Forest Service for consent, and the Forest Service can attach "conditions of its consent to protect surface resources" and site-specific lease stipulations. The DEIS states that "coal and oil and gas exploration and development are the most likely leasable minerals within inventoried roadless areas."

Federal oil and gas leasing already exists inside the areas potentially affected by this rule: "at present, there are 271 leases with a surface area of approximately 538,300 acres within the IRAs nationwide, excluding Colorado and Idaho, in authorized and producing status." The Eastern Region alone accounts for 411,600 of those acres. Separately, there are 14 authorized federal coal leases within potentially affected roadless areas, "totaling 13,050 acres," all on the Manti-La Sal National Forest in Utah, using underground extraction methods "with limited surface disturbance for exploration, powerlines, vent shafts and pipelines."

The 2001 Rule has always allowed exceptions for the mining law's "existing right of access." The DEIS reports that "since 2018 regional foresters reviewed and approved 19 exceptions related to locatable mineral projects," and that "the majority of which were exploration operations which required cutting or removing timber rather than road construction." The agency adds that it "does not track the number of proposals in relation to IRAs, so does not have data to indicate the relative amount of proposed plans of operations that are within or outside IRAs."

Under the 2001 Rule, locatable mineral access would continue exactly as today — road construction, reconstruction, and tree cutting remain an excepted "right of access" under the Mining Law, and the DEIS projects that "future exploration, mining, and mineral processing activities would continue to occur in IRAs where valuable deposits exist." For leasable minerals, "a no surface occupancy would be applied to new leases within IRAs, limiting where the lessee could construct roads," and the 2001 Rule "would continue to restrict road building associated with new leasable mineral exploration, both on-lease and off-lease... subject to valid existing rights." The DEIS acknowledges a public perception "that the 2001 Roadless Rule prohibitions have affected locatable mineral development," but states that reasonable access "is a right of access provided by the General Mining Law" regardless, and notes that of 11 large-scale mines producing in 2024, six already operate "partially or wholly within IRAs."

For locatable minerals, the DEIS states the legal effects are "generally the same as those under alternative 1" — access remains a Mining Law right either way — but adds that "to the extent that the perception of limitations from the roadless rule has prevented operators from proposing to conduct operations, that perception would be removed." For leasable minerals, new or modified leases could include road construction "as necessary in accordance with the terms of the lease," and such approvals "would be more likely to be authorized without the no surface occupancy lease stipulation, than alternative 1." When existing leases expire, renewals "would not need to consider the prohibitions associated with the 2001 Roadless Rule," and "the IRA boundary would not apply or be considered" in future lease-modification analyses — though a site-specific no-surface-occupancy stipulation could still be applied for reasons like preventing erosion on steep slopes.

Locatable-mineral effects under Alternative 3 are "the same as alternative 2." For leasable minerals, the alternative splits by geography: in the roughly 13 million acres that continue to be governed by roadless prohibitions, "effects would be similar to alternative 1" — new or modified leases get a no-surface-occupancy stipulation, and lease renewals on pre-2001 leases must still consider road-building restrictions. In areas where roadless designation no longer applies, "effects would be similar to alternative 2" — road construction for lease development "would be more likely without the no surface occupancy lease stipulation." Table 11 shows that within the areas Alternative 3 continues to treat as potentially affected, there are 377,500 acres across 271 oil and gas leases, and 12,727 acres across the same 14 coal leases in Utah — both slightly smaller totals than the nationwide Table 10 figures, reflecting the narrower geography this alternative covers.

The Conclusion states plainly that "across all alternatives, mineral and energy development would continue where there are existing rights or permits/leases" — the alternatives don't touch those. What differs is "new or expanded authorizations for leasable minerals (primarily oil and gas and coal)." Under Alternative 1, across all 40 million acres of potentially affected roadless areas (and also under Alternative 3 in the 13 million acres that remain roadless), new leasable-mineral authorizations "would be subject to review and include surface use restrictions, including limiting road construction." Under Alternative 2 (and Alternative 3 in areas no longer designated as roadless), "new authorizations and expanded authorizations could include road construction and reconstruction, depending on other legal requirements."

The document cites a substantial economic footprint for federal mineral and energy production: "in 2023, energy and mineral production from NFS lands contributed more than $7.6 billion to the Nation's economic growth in terms of Gross Domestic Product and supported approximately 37,800 jobs"; revenue from the 11 large mines described above "totaled about $1.4 billion" in 2024; "3.4 million acres of NFS lands are leased" for oil, gas, coal, phosphates, and geothermal; 2024 federal-lease production "produced commodities valued at over $4.8 billion"; and that activity "generated $533 million in revenue through royalties and other payments to the U.S. Treasury ($106 million from coal, $402 million from oil and gas, and $25 million from other leasable mineral commodities)."

In weighing sectors against each other, the document states that "the share of U.S. GDP associated with outdoor recreation is larger than the share of GDP associated with the mining (1.5 percent) or utility (1.6 percent) sectors," citing the U.S. Bureau of Economic Analysis 2025.

In discussing consistency with prior decisions, the document states that "this project approval is consistent with the analysis in the 2020 FEIS, which recognized that 'mining activities are expected to expand at existing sites, including Greens Creek on Admiralty Island.'"

The minerals discussion, alongside the timber, recreation, and roads sections, presents its economic case with precise dollar figures, job counts, and percentages, as detailed above.

About 21 million of the 40 million potentially affected acres (52 percent) are forested, and 96 percent of that forested area sits in western states. The Alaska and Intermountain regions alone hold 46 percent of it. Conifers dominate — 83.9 percent of forest type groups — led by fir/spruce/mountain hemlock (nearly 7 million acres), pinyon/juniper (3.7 million acres, "typically not harvested for sawtimber"), Douglas-fir (3 million acres), hemlock/Sitka spruce (2.8 million acres), and lodgepole pine (2.7 million acres). Hardwoods make up 16.1 percent, concentrated in the Appalachians, Midwest, and Intermountain region. The remaining 37 percent of the landscape (14.9 million acres) is non-forested — shrub/scrub, grassland, and wetland types.

Outside Alaska and Puerto Rico, roughly 16–17 percent of the forested area within the affected environment is old growth, 48–52 percent is mature, and 32–35 percent is young forest. Old growth is described as multi-layered stands that serve as "long-term carbon storage and unique habitat." Mature forest provides "biodiversity conservation, wildlife habitat, watershed protection, carbon storage, and opportunities for recreation, timber production, and cultural use."

U.S. forests generally function as a carbon sink, offsetting 12–19 percent of national CO2 emissions each year. The document states that in 2021, "forested lands within the national forest system sequestered 43.5 million metric tons (MMT) CO2," citing Domke et al. 2023. It also states that roadless areas hold about 5 percent of the stored forest carbon in the coterminous United States (0.9 billion Mg C), citing Birdsey et al. (2025). Carbon loss from insects, disease, and high-severity fire is described as "significant, long lasting, and expected in any of the alternatives," and the document states that under all alternatives IRAs "will continue to be managed primarily as forests and continue to sequester and store carbon."

According to the 2024 National Insect and Disease Risk Map, about 32 million acres (22 percent) of National Forest System forest in the lower 48 states are at risk of insect- and disease-driven tree mortality during 2024–2038. Risk varies widely by region — from 8.9 to 12.4 percent in the East to 17.5 to 50.4 percent in the West on NFS land outside designated areas. Within potentially affected roadless areas specifically, risk ranges from 12.7 percent (Eastern Region) to 34.2 percent (Northern Region). The mountain pine beetle is described as the primary tree-killing insect in the West, and has "impacted over 25 million acres in the western United States from 2000–2020."

Forest management in roadless areas is currently limited to "infrequent cutting, sale, or removal of small diameter trees for certain exceptions," further restricted by the 2001 Rule's prohibition on road construction. Since 2018, regional foresters approved 168 exceptions involving forest management, plus 14 more tied to road-related activity — mostly for hazardous fuels reduction or incidental removal tied to other permitted activities like mining. From 2014–2024, timber harvest within potentially affected roadless areas averaged approximately 500 acres per year, described as "inconsequential to overall nationwide levels." Non-commercial treatments (hazard tree removal, thinning, planting, and similar work) averaged about 1,700 acres per year.

The document states that "timber harvest is set to increase nationally due to urgent challenges to meet domestic lumber demand, reduce wildfire risk, and revitalize rural economies." Executive Order 14225 directs the Forest Service to expand timber production and streamline regulations. The One Big Beautiful Bill Act (Section 50301) directs the agency to sell at least 250 million board feet more per year, every year, for ten years, "subject to land management plan limits." The National Active Forest Management Strategy sets a goal of a 25 percent national increase in timber production.

Under the No Action alternative, forest management in roadless areas would continue at "approximately the same as the recent levels of 500 acres a year of timber harvest and 1,700 acres a year for non-commercial treatments." The DEIS states plainly that "even though overall agency timber harvest may increase nationally... timber harvest from IRAs under no action would not increase in either the short or long term," and that any harvest would remain "an extremely small portion of the agency's overall timber production."

Alternative 2 removes the 2001 Rule's prohibitions entirely, giving local land managers "the most flexibility" to permit timber harvest wherever land management plans and terrain allow it. The DEIS estimates that 4.8 million acres — 16 percent of forested area within potentially affected IRAs — are "likely operable" or "likely operable but complex" (accessible by mechanized equipment, within roughly a mile of roads, on moderate slopes) in areas where current plans allow harvest. The Intermountain Region has the most potential area (1.5 million acres), followed by the Northern Region (841,000 acres) and Pacific Southwest (608,000 acres); the Southwestern (200,000 acres) and Southern (148,000 acres) regions have the least. If all of this were harvested, the DEIS projects a national annual sawtimber increase of 253,000 to 557,000 hundred cubic feet (ccf) — a 5 to 10 percent increase over the current national harvest baseline of 5.5 million ccf per year.

Alternative 3 opens up timber harvest mainly within roaded roadless areas and the wildland-urban interface, rather than across all IRAs. The DEIS estimates about 4.3 million acres (21 percent of Alternative 3's smaller forested footprint) as likely operable or operable-but-complex where harvest is allowed, led by the Intermountain (1.2 million acres), Northern (700,000 acres), and Alaska (575,000 acres) regions. The projected national annual sawtimber increase is 219,000 to 501,000 ccf — a 4 to 9 percent increase — somewhat lower than Alternative 2. The DEIS states that under Alternative 3, "potential forest management activities would be more likely to be concentrated in areas near existing roads and within wildland-urban interface zones," and that activities outside those areas "outside the wildland-urban interface or more than 0.5 miles from roads" remain restricted.

Within the operable areas where land management plans generally allow timber harvest under Alternative 2, the DEIS estimates 11–16 percent is old-growth forest, 54–63 percent is mature, and 26–31 percent is young forest. It adds an important qualifier: about 50 percent of the old growth within those operable, harvest-allowed areas is composed of non-commercial forest types — aspen/birch, pinyon/juniper, and fir/spruce/mountain hemlock — meaning "not all remaining areas have potential for commercial timber harvest."

Both action alternatives are framed as opportunities to reduce insect and disease risk through active management. Under Alternative 2, 10 to 40 percent of acres within operable and operable-but-complex categories are at risk of insect/disease mortality, ranging from a low in the Pacific Southwest to 40 percent in the Northern Region. Under Alternative 3 the range is 9 to 43 percent, with the Northern Region again at the high end. The DEIS states that "forest management activities that include practices that reduce risk to forest insect and disease... could reduce insect or disease caused tree mortality," while also acknowledging that "changes in risk cannot be estimated nationally."

Under the action alternatives, road construction and timber harvest that remove vegetation would cause a loss of stored carbon proportional to harvest intensity, with permanent road construction causing a longer-term loss of sequestration capacity. The DEIS states these effects "would be small compared to the overall carbon within the forested landscape," that harvested areas retain sequestration capacity and, with required reforestation, "can be expected to maintain stored carbon levels over the long term" — though it also notes that "areas where timber was harvested may take several decades to return to similar levels of live biomass." Carbon storage in wood products is described as offsetting some of the loss.

The document's conclusion states that Alternative 1 would see "only small amounts of timber harvest," with vegetation trends "driven mostly by natural disturbances." Alternative 2 "would expand active forest management opportunities the most," with 4.8 million acres and a potential 5–10 percent sawtimber increase, offering "the greatest ability to promote forest health by reducing insect and disease risks." Alternative 3 "offers a more moderate increase than alternative 2," with 4.3 million acres and lower harvest potential, still promoting forest health "though at a smaller scale."

The document presents its acreage and harvest figures as best available estimates "for analysis and comparison purposes only," repeatedly cautioning that "it is not possible to fully predict actual areas where harvest would be proposed" and that land management plan restrictions could change over time through future amendments.

Wildfire "can create many environmental benefits" when it burns in the right place and time, but "in the wrong place at the wrong time, wildfires can threaten lives, homes, infrastructure, and important natural and cultural resources." The agency's overarching goal is "to balance fire suppression with the strategic use of fire, resource management, and national adaptation to fire presence." Treating hazardous fuels — especially near communities (the wildland-urban interface, or WUI) and municipal watersheds — is described as "a key priority under several national initiatives," including the Healthy Forests Restoration Act and the National Cohesive Wildland Fire Management Strategy.

Using agency fire-occurrence records and satellite burn-severity data for 2014–2024, the document reports that IRAs have far fewer fires per acre than other Forest Service lands: "the IRA estimates are essentially equivalent to those from...wilderness (12 fires per million acres per year) and represent less than one-third (29 percent) of the ignition density on other NFS lands (42 fires per million acres per year)." The total number of wildfires is "lowest within wilderness, followed by potentially affected IRAs, and highest on other NFS lands." Among fires with a known cause, 74–77 percent in IRAs and wilderness were naturally (lightning) ignited, versus a majority (57 percent) human-caused on other NFS lands, and "the incidence of human-caused fires generally increases with proximity to roads." Roadless areas do burn less often, but "the fires that do burn tend to reach larger sizes" — about 3.5 million acres (9 percent) burned in or from IRAs between 2014 and 2024, and over the longer 1984–2024 record, wildfire burned 20.5 percent of potentially affected IRAs, with 4.2 percent classified as high severity.

The agency evaluates risk using a national Wildfire Hazard Potential (WHP) index plus two more targeted tools: Community Wildfire Risk Reduction Zones (CWRRZs, a 1.5-mile buffer around clusters of buildings) and "high-priority firesheds" from the Wildfire Crisis Strategy. Across potentially affected IRAs outside Alaska, "42 percent of lands are classified as high or very high Wildfire Hazard Potential." About 26 percent of IRAs overlap high-priority firesheds, 15 percent overlap CWRRZs, and 24 percent overlap the HFRA-defined wildland-urban interface (WUI). The document concludes: "although less than one-quarter of IRA acreage is closely associated with community protection priorities, there are specific landscapes where IRAs may contribute to elevated wildfire risk for nearby communities."

The document is explicit that the current rule "does not prohibit and has not entirely prevented hazardous fuels reduction in IRAs" — there are "no prohibitions on the use of prescribed fire," and the rule "also provides exceptions for activities, including cutting and removing small diameter timber, to reduce wildfire risk." Agency tracking data (FACTS) show hazardous fuels reduction "completed on about 5 percent of the potentially affected IRA area over the most recent decade (fiscal years 2014-2024)." The document also cites prior research finding "the 2001 Roadless Rule did not meaningfully constrain hazardous fuel treatment activities when considering the number and area of treatments as a share of total forested land (Healey 2020)."

The document's core rationale states that "conditions across National Forest System lands have changed substantially, especially in the Western United States where many inventoried roadless areas are located, with increasing drought, extreme temperatures, wildfire frequency and severity, and insect and disease outbreaks," and that the 2001 Rule "limited the Forest Service's ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns."

Under the current rule, "the occurrence and severity of wildfires would likely remain similar to recent decades." Prescribed burning and activities that do not require road construction or tree cutting "would likely continue at similar to recent rates," while activities requiring tree cutting would still need an exception, whose "use would continue to be infrequent." The document states plainly that "the prohibition on road construction would likely limit opportunities for mechanical thinning and fire control," and that without new roads, "firefighters would continue to be challenged to identify safe, effective, and efficient places to contain fires before they spread to more accessible parts of the landscape, continuing the trend of larger and longer-duration fires in IRA[s]."

The Proposed Action would allow "additional active forest management, including some level of road construction," with the agency stating this "would provide the most local management flexibility for wildfire risk mitigation" and would "likely expand the area of timber harvest and hazardous fuels reduction treatments in potentially affected IRAs." Of the roughly 7 million acres of IRAs that intersect high-priority firesheds, the document estimates about 3.6 million acres (52 percent) are in "likely operable or operable-but-complex" condition for mechanical treatment. The DEIS also acknowledges a tradeoff: "with increased road construction, especially open-access roads, and other human activity, there could be increased hazard from human-caused ignitions," though it adds that "not all roads constructed under alternative 2 would be open for public access," and that public-access restrictions could limit added human-ignition risk.

The Modified Rule alternative is described as similar to the Proposed Action in the types of fire-risk tools available, but "would provide less flexibility than alternative 2 to target wildfire risk in large patches retained as IRAs." Under Alternative 3, "opportunities for mechanical hazardous fuels reduction and fire response would be concentrated in the WUI and roaded roadless, nearer to the communities they are intended to protect." Its wildfire-hazard profile is similar to Alternative 2 (42.7 percent high/very-high WHP, excluding Alaska) but with proportionately more overlap with high-priority firesheds, CWRRZs, and the WUI than the full IRA network.

The document reports that "initial attack success rates are high (more than 90 percent) for all land designations," but decline somewhat from other NFS lands (97.2 percent) to IRAs (94.4 percent) to wilderness (92.3 percent), and that mean days to contain an escaped fire rise from 27.4 (other NFS lands) to 46.6 (IRAs) to 57.9 (wilderness). Looking specifically at roads, the analysis found that "23.5 percent of NFS road length that interacted with wildfires was associated with successful containment" nationally, but this varied sharply by road quality: "the highest rates occurred on level 3–5 roads (40.9–51 percent), moderate rates on level 2 roads (20.8 percent), and the lowest rates on level 0–1 roads (12.7–13.4 percent)."

The document simultaneously presents evidence that (a) roads and higher-standard road access improve initial-attack success and containment outcomes, and (b) roadless and wilderness areas already have lower ignition density, fewer total fires, and comparable or lower burned-area percentages than roaded "other NFS" lands.

The document describes a "fundamental trade-off in wildfire management": "aggressive suppression across many decades has contributed to fuel accumulation and increased the likelihood that future fires...will burn under more extreme conditions and be more difficult to control – a dynamic often referred to as the wildfire paradox." It states that "many forested landscapes across the western United States remain in a deficit of fire relative to pre-settlement conditions." Within IRAs specifically, the most common recorded fuels-management activity by far has been managing naturally ignited fire for resource benefit (55 percent of reported accomplishments), followed by prescribed burning (25 percent), with mechanical treatment far more limited (11 percent rearrangement, 6 percent removal).

Elsewhere the document reports foundational figures for the current rule's track record — "an average of 500 acres per year of timber harvest and a total of 1.8 million acres of hazardous fuels reduction within IRAs managed under the 2001 Roadless Rule" — and, separately, that a comparative wildfire-emissions analysis across the alternatives "is not possible at this time," while acknowledging "resulting changes in wildfire will likely drive changes in total emissions from fire and subsequent air quality impacts over the long-term."

Executive Order 13751 defines an "invasive species" as a non-native organism whose introduction causes or is likely to cause economic or environmental harm, or harm to human, animal, or plant health. That order directs federal agencies to address invasive species and to avoid actions likely to make the problem worse. The DEIS explains that invasive plants can compete with native plants for water and light, change the mix of species in an area, reduce native plant populations, and alter vegetation structure — changes that also hurt wildlife and fish habitat. Forest Service policy (FSM 2900) directs the agency to review proposed projects for invasive-species risk, apply mitigation measures, and control existing infestations.

Ground-disturbing activities from machinery can transport seeds and reproductive plant parts and can create the kind of open, disturbed ground that lets existing or new invasive populations expand. Large, severe fires can do the same thing, since invasive plants often have a competitive advantage over native plants on recently burned or disturbed sites. The document also lists transport of seeds on vehicles using existing open roads, and spread of invasive plants already growing along roadsides, as contributing factors.

The document reports that "multiple invasive plant species were mapped" within the potentially affected inventoried roadless areas (IRAs), covering approximately 309,000 acres (270,787 acres under Alternative 3) — described as "less than 1 percent of the potentially affected environment area." It adds that "it is likely that there are populations that have been undetected and have not been mapped," and that 438 invasive plant species have been recorded in the affected environment area, with conservation rankings that vary state to state because each state uses its own management priorities and evaluation methods.

Under No Action, there would be "no direct increase" in invasive plants in the short term because no new activities would occur. But existing vectors — livestock, wildlife, motorized vehicles, roads, and trails — would keep contributing to a "gradual steady encroachment" of new invasive populations over the long term, especially if funding or access for detection and treatment is limited. Where invasives already exist, their spread would likely continue at current rates. The cost of treating existing infestations could rise slightly, and No Action would mean fewer opportunities for active management, such as fuels treatments, in roadless areas.

Beyond the ongoing spread described under No Action, road construction, timber harvest, and other development are "likely to increase in some areas" under the Proposed Action. Where this ground disturbance occurs, it has the potential to introduce and spread invasive species; the DEIS notes effects "may be minimal where the intensity of ground disturbance is low or where there are no existing invasive plant infestations." In the short term, new activity could introduce invasives where they don't currently exist; in the long term, increased disturbance could raise the spread risk of existing populations. The document states that Forest Service policy, land management plan direction, best management practices, and future project design features would reduce that likelihood, alongside an expected increase in the cost of detecting and treating new populations.

Alternative 3 affects fewer acres overall and has fewer mapped acres of invasive plants (270,787) than Alternative 2, though the document states this is still "less than 1 percent" of the affected area. The potential for ground disturbance from timber harvest, road construction, and other activities to spread invasive species is described as "similar to alternative 2," because the areas where these activities are operationally likely aren't expected to differ significantly between the two alternatives. The DEIS concludes the alternatives "are not expected to differ significantly" in their contribution to invasive species spread.

No Action would cause "no direct increase" in invasive plants because no project actions would occur. Alternatives 2 and 3 "may provide opportunities" for activities that could increase the extent or number of invasive species, most likely in areas where ground disturbance occurs — but those alternatives would also allow fuel-load reduction that lowers wildfire risk, and wildfire itself creates openings that invasive plants can exploit. The document concludes that with compliance with applicable laws, forest plan standards and guidelines, and future project design features to mitigate introduction and spread, the effects of Alternatives 2 and 3 "are not expected to greatly increase."

In its summary of public comments, the document states that "commenters identify road construction and resulting vehicle traffic as the leading cause of invasive species spread within national forests."

The invasive species discussion describes the incremental risk from Alternatives 2 and 3 only in general terms — that ground disturbance "could potentially increase the extent or the number of invasive plant species" — without an acreage projection, spread-rate estimate, or dollar cost.

The comment-summary appendix reports that approximately 99 percent of comment letters received were "generally opposed" to the proposed rescission, while approximately 1 percent were "generally in support," including opposition themes covering invasive species along with drinking water and carbon storage.

Soil, water, and air conditions vary widely even without any human activity, but the document identifies road construction, timber harvest, prescribed burning, and similar activities as the main added disturbances. The most common effects it lists are "loss of vegetation, soil erosion and compaction, loss of soil productivity, increased potential for landslides, reduced transpiration... increased water runoff, reduced water quality, and periodically reduced air quality." Roads specifically "have long been recognized as a substantial human-caused source of soil and water disturbances in forested environments." Most impacts occur during initial construction and decrease as roadside vegetation reestablishes and disturbed soil stabilizes — except landslides, which "persist when a road permanently undercuts unstable soils or landforms, or when roads are continually disturbed by road maintenance." The document also states plainly that "insufficient maintenance funding is a key reason for the lack of adequate road maintenance," and that poorly maintained roads cause greater impacts as culverts plug and drainage is compromised.

Heavy equipment used in timber harvest and road construction can compact soil, displace or mix surface organic matter into mineral soil, or expose low-productivity subsoil. Compaction is described as "densification of an unsaturated soil body by the reduction of its air-filled porosity," and it is linked to reduced root growth, altered nutrient cycling, and decline in microbial health. On skid trails, bulk-density increases (a measure of compaction) can extend up to 5 meters across the trail and 2 meters beyond it. Severe compaction can prevent seedling roots from penetrating the soil, causing seedling death, deformity, or reduced growth. Organic matter matters beyond nutrients too: "1 to 6 percent organic matter can hold 5 to 25 percent available water," so its loss or displacement reduces a site's capacity to hold water.

Using the Watershed Condition Classification, the document rates soil condition in watersheds containing potentially affected IRAs as "Good," "Fair," or "Poor." The Southern region rates 43 percent Poor, Eastern 28 percent Poor, Southwestern 31 percent Poor, and Intermountain 13 percent Poor (with another 52 percent only "Fair"). By contrast, Northern, Rocky Mountain, Pacific Southwest, and Pacific Northwest regions each have more than 75 percent of watersheds rated "Good."

The document states that sediment "within timber harvest units is most strongly related to road construction and associated facilities," and that skid roads, trails, and log landings "can contribute up to 90 percent of the sediment generated by timber sale activity." Best Management Practices (BMPs) are credited with reducing, though not eliminating, these impacts — the document reports compliance rates of 85 to 98 percent and quotes a 2018 source that BMPs "may not be completely effective, but they do provide a level of protection that the states and the Environmental Protection Agency judged sufficient to meet the goals of the Clean Water Act." Elsewhere, the document asserts that "peer-reviewed studies estimate that roads produce 100–300 times more sediment per unit area than undisturbed forest."

Tree roots reinforce soil and increase its shear strength; after logging, roots decay over 5 to 20 years, with landslide risk highest 5 to 10 years after harvest. Removing canopy cover raises soil moisture and pore-water pressure, making saturated slopes more prone to failure. Roads add further risk: they create artificial cuts and fills, concentrate drainage, and can become "hydrologically connected" networks that route water and sediment directly into streams. The document cites research finding that "landslides and debris flows are 6 to 9 times more likely adjacent to forest roads." Modeling shows the Pacific Northwest and Pacific Southwest with the highest landslide-potential ratings: 69 percent and 56 percent of their watersheds containing IRAs are rated "Poor" for slope stability, respectively.

Under Alternative 1 (No Action), general prohibitions on road construction and tree cutting mean "little potential for altering current soil and water conditions," with low likelihood that any road-building under the rule's existing exceptions would land on highly sensitive or unstable soils. Under Alternative 2 (Proposed Action), additional roads, timber harvest, and related activities are "reasonably foreseeable," and impacts would be "reduced using mandatory National best management practices and local land management plan compliance" — but the document also reports that only 12 percent of Intermountain-region IRAs and 6 percent of Southwestern-region IRAs are classified "likely operable," while 40 percent of Southeastern-region IRA acreage is. Under Alternative 3 (Modified Rule), the pattern of soil concern is described as "consistent with alternative 2," but over a smaller affected area; land farther than half a mile from existing roads keeps roadless prohibitions, with effects "similar to alternative 1."

The EPA delegates Clean Water Act implementation to states and tribes, and the Forest Service is often the designated water-quality management agency on National Forest System land under agreements with states. Streams identified as "impaired" go on a Section 303(d) list requiring a Total Maximum Daily Load calculation. Since 2012 the agency has used National Core Best Management Practices to help meet these requirements. Harvest and roads can raise nutrient levels (nitrogen, phosphorus, potassium, calcium) in streamflow — nitrogen shows the most abrupt change — but these "usually return to normal in 1 to 4 years." Water temperature can rise where groundwater is intercepted, channels widen or shallow, or riparian shading is lost, with smaller and shallower streams more susceptible. By region, watershed water-quality ratings (Table 33) show Rocky Mountain highest (91 percent "Good," 0 percent on the 303(d) impaired list), while the Pacific Northwest — despite being grouped with the generally better-rated western regions — has nearly 40 percent of its IRA-containing watersheds carrying 303(d)-listed impaired streams.

The effect of harvest and roads on flooding shrinks as watershed size increases, because extra flow from smaller disturbed areas becomes less noticeable once it joins larger flows downstream. Large storm events are driven mainly by precipitation volume, not land use. Research cited in the document indicates at least 20 to 30 percent of a watershed's basal area typically must be removed to produce a measurable increase in annual water yield (20 to 25 percent in Eastern forests specifically). Flows generally return to normal 6 to 10 years after harvest in humid regions, and up to twice as long in drier ones. Timber harvest can measurably increase annual water yield; roads generally do not, mainly because harvest covers more area than roads do. However, the document also states that "hydrologic recovery after road building takes much longer than after forest harvest because roads modify physical hydrologic pathways but harvesting principally affects evapotranspiration processes."

Forests supply drinking water for over 150 million people in the United States, and the country's 749 million forested acres provide more than half the national water yield in the lower 48 states. About 74 percent of U.S. drinking-water withdrawals come from surface-water sources, and national forests provide roughly 15 percent of the nation's runoff. More than 7,000 municipal water intakes sit in watersheds containing potentially affected IRAs, and about 24 million people (outside Alaska) use water that originates in those watersheds. The Pacific Southwest region alone serves nearly 5 million people from IRA-containing watersheds; the Intermountain region serves over 1 million. Looking forward, the document cites research projecting streamflow reductions of 10 to 45 percent across western states over the next half-century as temperatures rise and snowpack declines, and notes that "a 10 percent drop in streamflow is considered calamitous by municipal water districts."

Under Alternative 1, the document states there is "little risk of potential adverse effects" and it "provides the greatest protection of water quality," with water yields and runoff patterns "generally unaltered from natural conditions." Under Alternative 2, road construction and native-surface roads are called "the largest source of sediment related to timber harvest operations," and sediment delivery is described as "a major source of water quality degradation," though BMPs are expected to "reduce these impacts to levels congruent with the Clean Water Act." The Eastern and Southern regions are called most susceptible to further impacts because of their land-use history, and they also have the largest share of "likely operable" IRA acreage (over 40 percent in both). The Northern Rockies and Pacific Northwest are flagged too — over 20 percent "Poor" water quality in the Northern Rockies and 40 percent impaired streams in the Pacific Northwest — but only 16 and 21 percent of those regions, respectively, are "likely operable." Under Alternative 3, the pattern of concern mirrors Alternative 2 but over a smaller area: more than 5,000 municipal water intakes rather than over 7,000, and nearly 4 million people served in the Pacific Southwest rather than nearly 5 million.

Direct discussion of fish and aquatic habitat in this material is limited. The water-yield section notes that in hardwood forests, harvest can supplement late-summer low flows, which "can be beneficial to fish and other aquatic organisms during water-stress periods." Beyond that, the document states that NOAA's National Marine Fisheries Service "determined that listing of the Gulf of Alaska Chinook salmon under the Endangered Species Act is not warranted," and that a 2020 Forest Service EIS "found that... overall effects to fish habitat are expected to be minimal whether the Roadless Rule is in place or not, because of the strong protections to fish habitats provided by Forest Plan standards and guidelines and the riparian management strategy."

Under the Clean Air Act, the EPA sets National Ambient Air Quality Standards (NAAQS) for pollutants including ozone, particulate matter, and nitrogen dioxide (Table 37), and designates areas that fail to meet them as "nonattainment," requiring a State Implementation Plan. Class I areas — national parks over 6,000 acres and wilderness over 5,000 acres that existed when the 1977 Clean Air Act amendments passed — receive the strongest protection against air-quality deterioration. The document reports that less than 5 percent of inventoried roadless area overlaps nonattainment or maintenance zones in every region except the Pacific Southwest, where the overlap is far larger: 40.6 percent of the region's roadless acreage for ozone nonattainment, 19.2 to 19.3 percent for PM2.5, 27.2 percent for PM10, and 6.7 percent for NO2 (maintenance). The document is careful to note that this overlap "does not imply that nonattainment or maintenance in these areas is the result of emissions on National Forest System lands" — only that new emissions there could add to an existing problem.

Under Alternative 1, the vast majority of IRAs are currently in attainment, and holding activity levels steady means emissions "would not be expected to change significantly," with future air-quality trends driven mainly by sources outside IRAs. Under Alternatives 2 and 3, potential emission sources include smoke (from prescribed and wildland fire), dust and exhaust from road construction and use, tree cutting and removal, and mineral development. The document frames the net effect as "more frequent short-duration smoke events from prescribed fire and fuels treatment but greater air-quality resilience due to reduced risk of catastrophic wildfire." A summary table (Table 39) rates relative emissions potential from "+" (lowest) to "++++" (highest): road construction, tree cutting, prescribed fire, and mineral development are each rated "+" under No Action and "++" under both action alternatives — but wildland fire itself is rated "++++" (the highest mark in the whole table) under No Action, and "+++" under both Alternative 2 and Alternative 3.

The conclusion states that Alternatives 2 and 3 "would have variable effects on soil and water resources" depending on existing land management plan direction, noting that "many of these plans already have protections in place." Still, it is "reasonably foreseeable that additional road construction and timber harvest eventually could occur, and these activities could contribute to reducing forest soil productivity and water quality," with impacts "more likely in the 'operable' areas." Any future site-specific projects would still have to comply with the National Forest Management Act, NEPA, the Clean Water Act, and the Multiple-Use Sustained-Yield Act, and plan components must ensure management does not "lead to permanent impairment of the productivity of the land." For air, the conclusion calls immediate effects under Alternatives 2 and 3 "minimal," while noting that new activities "could eventually occur" and that changes in wildfire emissions are likely to have "the largest potential effect on air resources at the national scale" — with the Pacific Southwest again singled out as differing substantially from other regions.

The potentially affected environment — the roadless areas at stake in this rulemaking — "provides habitat for more than 300 threatened, endangered, and proposed species." It also contains "79 final or proposed critical habitats designated under the Endangered Species Act for species managed by USFWS" and "19 critical habitats" managed by the National Marine Fisheries Service (NMFS), plus habitat for "thousands of Regional Forester Sensitive Species (RFSS) and Species of Conservation Concern (SCC)" — with more than 3,500 RFSS listed agency-wide. Five coniferous forest types make up about 75 percent of the forest cover in these areas and "support a host of threatened, endangered, and proposed species."

Habitat "fragmentation" — breaking large areas into smaller, more isolated pieces — is described as one of the central threats to biodiversity. The DEIS cites "a synthesis of fragmentation experiments spanning five continents and 35 years" finding that fragmentation "reduces biodiversity by 13 to 75 percent," with effects "greatest in the smallest and most isolated fragments." Separately, the document explains that "connectivity" — how easily animals and natural processes can move across a landscape — is "crucial for maintaining biodiversity," citing the federally threatened grizzly bear as an example of a species that "require[s] connected landscapes across broad geographic extents" to survive and recover.

Under Alternative 1, the 2001 Roadless Rule's prohibitions on road construction and timber harvest would continue, with only limited exceptions. Since 2018, "regional foresters reviewed and approved 168 exceptions" to cut trees, of which "eight exceptions approved tree cutting for the explicit purpose of 'improving threatened, endangered, or sensitive species habitat.'" The DEIS states that under this alternative, "potential adverse effects to terrestrial and aquatic species and habitats from fragmentation, loss of connectivity, edge effects, and human disturbance are much less likely" than under the other alternatives, and that "large contiguous tracts of land are more likely to be maintained."

Alternative 2 removes the roadless prohibitions across roughly 30 million acres, and the DEIS calls an increase in road construction, reconstruction, and timber harvest "reasonably foreseeable." It catalogs a long list of potential adverse effects tied to roads and logging: habitat loss and fragmentation, edge effects, spread of invasive species, barriers to movement and dispersal, increased human-wildlife conflict, direct mortality (including road-kill and, for some mammal populations, roads as "the greatest source of mortality"), and loss of genetic connectivity — citing examples ranging from elk avoiding roaded habitat to declines in Sierra Nevada fisher genetic connectivity near roads. It also lists potential benefits, such as easier access for habitat restoration, creation of early-successional habitat some species use, and improved access for invasive-species removal and fuels work.

Alternative 3 removes the roadless prohibitions only within roughly ½ mile of existing roads or within wildland-urban interface (WUI) areas, affecting about 17.9 million acres outside the Tongass National Forest — versus about 30 million acres under Alternative 2 — while keeping prohibitions on about 13 million acres. The DEIS concludes that adverse effects "are similar to what is described under alternative 2, but generally to a lesser extent," and that the risk of fragmenting "large contiguous tracts of undisturbed areas" is lower because the areas affected would be close to existing roads rather than in core roadless interior.

In its conclusion, the DEIS states that "impacts to biodiversity would likely be the least under alternative 1," more frequent and broader under Alternative 2, and intermediate under Alternative 3. It reiterates that under any alternative, current Forest Service land management plans are legally required to "maintain the diversity of plant and animal communities and support the persistence of native species," and that future site-specific projects would still have to comply with the Endangered Species Act, the Migratory Bird Treaty Act, and other applicable law.

Section 7(a)(2) of the ESA requires federal agencies to ensure their actions don't jeopardize listed species or destroy designated critical habitat. The DEIS states that "draft biological assessments have been prepared" and that, "based on these findings, we anticipate initiating consultation under Section 7(a)(2) of the ESA and that" USFWS and NMFS "will issue a Biological Opinion." Under Alternative 2, "preliminary findings resulted in a 'may affect, likely to adversely affect' determination for 327 species and 71 designated critical habitats." The document adds that "where information is lacking the Forest Service erred on the side of making the more impactful determination," and that "this Draft EIS presents preliminary findings."

Beyond ESA-listed species, the Forest Service separately tracks Regional Forester Sensitive Species (RFSS) to keep them from needing ESA listing in the first place. Under Alternative 2, the DEIS reports a "'may effect individuals or habitat'" determination — one that does not rise to a loss of species viability or a trend toward federal listing — for 3,490 sensitive species, broken out by taxonomic group and region in the document's Table 40. Under Alternative 3, the DEIS expects the number of affected sensitive species to be "similar or reduced" relative to Alternative 2, and states plainly that "no determinations of a loss of species viability or trend toward federal listing were made" under either action alternative.

For most affected wildlife, the document's biodiversity analysis works from general, agency-wide land management plan requirements — that plans must "maintain the diversity of plant and animal communities" and "support the persistence of native species" — applied across the roadless-area landscape as a whole.

Under Alternative 3, "responsible officials... may propose boundary modification to the Chief" for reasons including "geographic features" or "land management plan management areas," and a modification "is not required to perform work done under an exception." The provision calls for a 30-day public comment period on proposed modifications.

The DEIS identifies "invasion of non-native species" as one of the biodiversity effects tied to roads, noting that "non-native plants... are twice as common within 500 feet of a road," and that once established, "many of these non-native species are extremely difficult or impossible to eradicate." Within the potentially affected environment, invasive plant species were mapped covering roughly 309,000 acres under Alternative 2 (270,787 acres under Alternative 3) — "less than 1 percent of the potentially affected environment area" — out of 438 invasive plant species recorded overall.

The document's Purpose and Need section explains the rationale for rescission largely in terms of the 2001 Rule's effect on active management: it states that the Rule "limited the Forest Service's ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests," which the DEIS ties to forest health challenges.

The national forests that contain today's inventoried roadless areas receive about 125 million visits a year — 76 percent of the 164 million total visits to all National Forest System lands. Within the potentially affected IRAs, the document's own mapping finds that 90 percent of the land is in the least-developed recreation categories: 33 percent "Primitive" and 49 percent "Semi-Primitive Non-Motorized," using the Forest Service's Recreation Opportunity Spectrum (ROS), a six-class system ranging from Primitive to Urban that describes how developed or undeveloped a setting is. The 2001 Roadless Rule itself identified "natural appearing landscapes with high scenic quality" and "primitive, semi-primitive nonmotorized and semi-primitive motorized classes of dispersed recreation" as characteristics that often define these areas.

Recreation settings are classified using ROS: Primitive, Semi-Primitive Non-Motorized, Semi-Primitive Motorized, Roaded Natural, Rural, and Urban. Scenery is separately tracked using Scenic Integrity Objectives (SIOs) — Very High (unaltered), High (appears unaltered), Moderate (slightly altered), and Low (appears altered) — which describe how much a landscape can be changed and still meet a land management plan's goals. The DEIS notes that its national ROS mapping "is not intended to be exact" and that "finer-scale inaccuracies may exist," since it wasn't verified against local knowledge.

Under the current 2001 Roadless Rule, "the scenic quality would remain substantially unaltered by future management activities," and existing ROS settings "would be maintained" because road construction and timber harvest stay tightly restricted. The rule does allow road construction "in limited situations," and where a permanent road is built and opened to public motorized use, the setting there could shift from non-motorized to motorized — but the DEIS calls the overall effect "negligible."

Under the Proposed Action, road construction and reconstruction are "reasonably foreseeable," and if new or reconstructed roads are opened to public motor vehicle use, "existing ROS settings could change to a more developed setting class." The DEIS's Table 41 shows the potentially affected IRAs are 33 percent Primitive, 49 percent Semi-Primitive Non-Motorized, 8 percent Semi-Primitive Motorized, and 8 percent Roaded Natural. Within the areas identified as operable for timber and road work, semi-primitive non-motorized land makes up nearly 9 million acres — about 70 percent of the operable area — and the DEIS estimates "an average of about 52 percent" of the semi-primitive non-motorized, semi-primitive motorized, and roaded natural settings in the affected area "are more likely to be impacted." Primitive settings, by contrast, make up only 4 percent of the operable area, because operability depends on proximity to existing roads and infrastructure.

Under the Modified Rule, the 13 million acres that would remain inventoried roadless would see no ROS change, "as described for alternative 1." Where the rule's protections are removed, the DEIS says effects "would generally be the same as alternative 2," but because the affected footprint is smaller, "fewer acres of all recreation settings could be impacted overall" — about 12 million fewer non-motorized acres than under Alternative 2 (roughly 5 million fewer primitive acres and almost 7 million fewer semi-primitive non-motorized acres).

The existing scenic integrity of the potentially affected IRAs "is generally high or very high," which the DEIS attributes to decades of limited road construction and commercial timber harvest under the 2001 Rule. Scenery matters, in the document's words, because "high-quality scenery, especially scenery with natural-appearing landscapes, enhances people's lives and benefits society," contributes to community sense of place, and supports tourism. Observing scenic views is described as the second most common activity associated with national forest visits.

Timber harvest effects on scenery are "often the most noticeable for a few years after implementation," especially up close (within about half a mile), though effects can remain visible longer at greater distances on hillsides and mountain slopes. New road construction "is often noticeable by exposing light-colored soils" and by cutting breaks in the tree canopy, with effects potentially visible from foreground to background distances "depending on location and design." Under Alternative 1, in the limited areas where permanent roads are built, "the scenic integrity could change from high-to-moderate or low." Temporary roads, once rehabilitated, are said to "revegetate quickly" and visually recover "within a few years."

Dispersed recreation — activities outside developed sites, including hunting, fishing, hiking, horseback riding, mountain biking, OHV use, and dispersed camping — is described as "typified" in inventoried roadless areas, where "minimal infrastructure, limited human disturbance, and a focus on resource protection over user comfort align with the preferences of visitors seeking quiet, challenge, and low-impact outdoor experiences." Under Alternative 1, "the overall availability of inventoried roadless areas for dispersed recreation would remain high." Under Alternative 2, there would be "some reduction in areas that provide quiet, remote settings," while new permanent roads "could provide increased public access to dispersed recreation opportunities... but may result in reduced availability of recreation opportunities in quiet, remote settings," with "more use conflicts than Alternative 1 and 3." The DEIS also states Alternative 2 "could provide increased opportunities for dispersed camping, hunting, and climbing access" where new roads are built. Alternative 3 is described the same way but to a lesser degree than Alternative 2.

The potentially affected IRAs contain 21,808 miles of trail, including 1,127 miles of National Scenic and Historic Trails (NSHTs) and 981 miles of National Recreation Trails. The DEIS states Alternative 2 "has the highest potential for active management activities and is most likely to result in negative effects to 920 miles of National Recreation Trail and 1,075 miles of National Scenic and Historic Trails," with 268 of those NSHT miles in areas rated operable and 316 more rated "operable but complex." Under Alternative 3, a total of 680 NSHT miles are affected, with 268 operable and 122 operable-but-complex.

Nationally, there are 10,755 developed recreation sites (campgrounds, trailheads, and similar higher-development facilities) with an estimated $1.28 billion in deferred maintenance. About 500 developed sites — 70 percent of them campgrounds — sit within the potentially affected IRAs. Under Alternative 1, new development stays concentrated outside roadless areas because roads can't be built or upgraded inside them. Under Alternative 2, new permanent roads could support "backcountry recreation needs such as low development scale trailheads, primitive campsites, or staging areas, rather than large-scale infrastructure like new campgrounds." Deferred maintenance costs are expected to keep rising under every alternative as demand grows and existing facilities age.

The Forest Service holds more than 24,000 active recreation special-use permits, which generated about $150 million in fee revenue in fiscal year 2024. Outfitters and guides for hunting, fishing, rafting, and sightseeing "provide most recreation opportunities authorized by special use permits in roadless areas," operating in semi-primitive settings "free of the urban influence." Fifteen of the Forest Service's 127 ski-area permits sit in or adjacent to IRAs. Under Alternative 2, the DEIS states that increased road construction and timber harvest "could reduce the supply of unroaded or backcountry areas available for outfitter and guide assisted dispersed recreation opportunities," though it also notes some guides might see new opportunities from road-based access, and that timber-harvested areas could attract use for hunting or wildlife viewing even as others avoid recently cut areas.

Inventoried roadless areas adjacent to wilderness "serve as natural transitions" and, under Alternative 1, "can be more easily accessed by visitors than designated wilderness... thereby relieving some recreational use pressure on designated wilderness," with the threat to wilderness character described as "low overall." Under Alternative 2, the DEIS states that "this trend of shifting human patterns, increased resource management activity, and reduced ecological integrity near designated wilderness could increase the threat to the qualities of wilderness character of these areas."

In its own summary, the DEIS concludes that Alternative 1 preserves "the most opportunities for quiet, remote and self-reliant recreation," Alternative 2 "has the greatest potential impact on recreation settings and scenery" — including about 12 million more non-motorized acres potentially affected than Alternative 3, plus the greatest risk to National Recreation Trails and NSHTs — and Alternative 3 falls in between, preserving more quiet and remote settings than Alternative 2 while allowing more flexibility than Alternative 1.

Cultural resources are broadly defined (Forest Service Manual 2360.5) to include "objects and specific locations linked to human activity, occupation, or use" — pre-contact (indigenous) and post-contact historic districts, archaeological sites, buildings, structures, artifacts, sacred sites, cultural landscapes, and traditional cultural places. The DEIS notes that "for Tribes, natural resources are cultural resources, and therefore it is impossible to fully list every type of potential cultural resource in this analysis."

Under the National Historic Preservation Act, a "historic property" is "any prehistoric or historic district, site, building, structure, or object included on, or eligible for inclusion on, the National Register [of Historic Places]" (54 U.S.C. 300308). To be eligible, a resource must meet at least one of four criteria — association with significant historic events (A), association with significant persons (B), distinctive design or construction characteristics (C), or the likelihood of yielding important historical information (D) — and is usually at least 50 years old (36 CFR 60.4). A "traditional cultural place" is eligible because of its association with the practices or beliefs of a living community, rooted in that community's history and important to its continuing cultural identity; Tribes and Tribal members may still exercise rights to visit such places under laws including the American Indian Religious Freedom Act and Executive Order 13007 (sacred sites).

"Ground disturbance, including whether areas have previously been disturbed, is a key consideration when determining impacts to cultural resources," and "new ground disturbance may damage historic properties and other cultural resources." Activities that stay within the extent of previous disturbance (from past logging, natural disasters, etc.) do not count as new ground disturbance. Visual changes to the landscape can also affect a cultural resource, particularly where the change affects culturally or historically significant features.

"The rulemaking does not authorize any activities that can affect historic properties." Future actions in inventoried roadless areas will require project-level, site-specific review under Section 106 of the National Historic Preservation Act.

Evidence of indigenous habitation dates back 13,000 years (Surovell et al. 2022) to 23,000 years (Pigati et al. 2023), though most Tribes cite occupation "since time immemorial." Pre-contact sites range from lithic quarries and habitation sites to sacred locations and burial grounds, and National Forest System lands are Tribal ancestral lands with treaty-reserved rights. Post-contact history includes Spanish colonization in the 16th century, westward expansion driven by laws like the Indian Removal Act of 1830 and the Homestead Act of 1862 — which led to forced removal of Tribes from their homelands — and later mining camps, homesteads, and the timber-driven growth that led to federal forest management beginning in 1876 and the Forest Service in 1905. Depression-era Civilian Conservation Corps structures, including guard stations and fire lookouts, "remain significant cultural resources."

Under the 2001 Rule, timber harvest and road construction remain limited, with only "limited exceptions," which are "expected to continue to be infrequent." Any ground-disturbing activity that does occur would still trigger Section 106 review, including early Tribal consultation, plus land management plan compliance and NEPA review.

Increased timber harvest and road construction/reconstruction under these alternatives "could have long-term negative effects on cultural resources including historic properties." Effects would be more likely where land management plans allow these activities and on land operable for mechanical equipment. Under Alternative 3, the potentially affected area is limited to wildland-urban interfaces and areas within half a mile of roads, so "the potential for impacts to cultural resources would be on less area." Neither alternative authorizes any specific project; future proposals would still require Section 106 review and early consultation with Tribes and other consulting parties.

"New road construction always has the potential to impact cultural resources when roads are built in undisturbed areas," because it creates substantial new ground disturbance, and "many roads are built on historic travel routes often dating to thousands of years before the present." Roads can sometimes be aligned to avoid known sites, "but often complete avoidance is impractical." Road reconstruction and repair within an existing footprint has little to no impact, but "road widening, realignments, and new roads usually have negative long-term impacts on cultural resources" and "may meet the threshold of an 'adverse effect' to historic properties" under Section 106's implementing regulations (36 CFR 800). An adverse-effect finding triggers the resolution procedures at 36 CFR 800.6, "which usually requires a memorandum of agreement." Beyond direct disturbance, "by making cultural resources sites more easily accessed by the public, roads provide increased opportunities for vandalism, looting, and inadvertent degradation of cultural resources from human foot and vehicle traffic."

The Forest Service "often avoids and minimizes impacts to archaeological sites and other cultural resources by flagging them for avoidance." Vehicles and machinery that create little to no new ground disturbance "will likely not have significant impacts," while heavy machinery — and even smaller tools such as a come-along — can cause substantial disturbance through dragging or skidding. Post-harvest erosion can affect cultural resources but can be mitigated with seeding and mulching. In roadless areas, "early and regular Tribal consultation can inform project design to avoid, minimize, or mitigate potential visual impacts to Tribally important cultural landscapes, sacred sites, and traditional cultural places."

Throughout this section, the document commits to "early consultation with Tribes and other consulting parties" for future timber and road projects, alongside State Historic Preservation Officers, to identify and evaluate historic properties and resolve adverse effects. Elsewhere the DEIS reports that the Forest Service received 64 requests for consultation, with 29 consultations held and 5 more scheduled.

Elsewhere in the document's background discussion, the 2001 Roadless Rule's own list of features that often characterize inventoried roadless areas is recited, including "traditional cultural properties and sacred sites" as one of nine such values.

The Forest Service has legal obligations under the Constitution, treaty rights, and federal law "to protect and preserve the inherent rights of American Indians into perpetuity," including access to lands, use of forest products, freedom to practice traditional religions, and protection of sacred sites and cultural resources. Tribal sovereignty is "not a power delegated to Tribes by Congress but is instead an inherent power that has never been extinguished" (citing Worcester v. Georgia). A trust relationship binds the federal government, which "has charged itself with moral obligations of the highest responsibility and trust" (Seminole Nation v. United States, 316 U.S. 286, 1942). Treaties are typically not grants of rights to Tribes but grants of rights from Tribes to the United States, with Tribes reserving whatever wasn't specifically ceded — including, in many cases, rights to lands, fishing, hunting, water, and other goods and services. Ratified treaties are the supreme law of the land and can be changed only by Congress. The document also notes that 9 million U.S. residents identify as American Indian and Alaska Native, either alone (2.7 million) or in combination with other races (6.3 million).

Based on "preliminary responses to the Notice of Intent, formal written consultation requests from Tribes, and documentation from consultations," the agency identifies six themes: (1) an "intimate relationship with and broadscale reliance on forest resources for subsistence use, since time immemorial"; (2) legally binding requirements for shared decision-making when proposed actions may affect trust assets; (3) interest in co-stewardship for tribally led forest restoration; (4) the importance of incorporating Traditional Ecological Knowledge through co-management agreements; (5) net economic benefit to Tribes from protecting intact landscapes for ecotourism and recreation; and (6) "clear and consistent strong opposition to the Roadless Rule Rescission citing past lawsuits that resulted in favoring Tribal interests (with a few exceptions)."

The analysis uses three indicators to compare alternatives: Access (Tribes' ability to reach treaty resources, sacred sites, or other important areas), Resource Usability (whether the quantity and quality of resources meet Tribal needs), and Disturbance (any activity threatening treaty resources, sacred sites, or other areas of importance). The DEIS states these are assessed "qualitatively based on consistent feedback received from Tribes," while acknowledging that "both Tribes and the Forest Service have some quantitative information" in local, regional, and national databases. Site-specific Tribal consultation is described as "essential to understanding what access, uses or resources may be affected."

Congress's 1970s Indian Self-Determination and Education Assistance Act (Public Law 93-638, 25 U.S.C. 5301) created a contracting framework letting Tribes take on management functions on federal land. The 2018 Farm Bill (Public Law 115-334) expanded this authority to Forest Service Tribal Forest Protection Act (TFPA) projects, giving the agency authority to enter "638 self-governance compacts" with Tribes. The first such Forest Service agreement was signed September 9, 2020, with the Tulalip Tribes, for a demonstration project restoring beaver habitat and protecting salmon on the Tulalip's ancestral and treaty-protected lands.

Executive Order 13007, issued in 1996, requires federal agencies to protect and preserve access to and ceremonial use of Indian sacred sites and to avoid adversely affecting their physical integrity. A sacred site is defined as any "specific, discrete, narrowly delineated location on Federal land" identified by a Tribe or authorized religious representative as sacred, "provided that the Tribe or appropriately authoritative representative of an Indian religion has informed the agency of the existence of such a site."

Using the definition at 36 CFR 219.19, the DEIS describes Indigenous Knowledge as "the body of observations, oral and written knowledge, innovations, practices, and beliefs developed by Tribes and Indigenous Peoples through interaction and experience with the environment," accumulated "since time immemorial" and passed down through generations. The document states that Tribes "see themselves as inseparably intertwined with the land and natural world and have a responsibility to steward lands in perpetuity."

Under Alternative 1 (No Action), timber harvest and road construction would "continue to be infrequent and only where Responsible Officials approve exceptions." When exceptions are granted, effects would resemble those under Alternatives 2 and 3 "but would likely happen less frequently and affect less land area." Under Alternatives 2 (Proposed Action) and 3 (Modified Rule), "additional timber harvest and road construction and reconstruction are reasonably foreseeable" and "could have long-term negative effects on Tribal rights and interests." Neither alternative "would authorize site-specific actions" directly — those still require future project-level review. Under Alternative 3, outside the Tongass National Forest, the affected area is limited to wildland-urban interfaces and areas within half a mile of existing roads, so impacts "would be similar" in kind to Alternative 2 "but over less area."

New roads "may fragment or obscure ancestral trails" that the document describes as "not merely transportation corridors but ceremonial pathways and links to oral histories and traditional knowledge." Increased road access "may lead to unauthorized public access, vandalism, or desecration of sacred sites," which "can erode the sanctity and privacy required for traditional practices." Roads and logging "can compromise the acoustic and visual integrity" of undeveloped areas that many Tribes rely on for "quiet, solitude, and spiritual renewal."

Timber harvest and road-building "can increase sedimentation, alter hydrology, and impair fish and aquatic organism passage," directly affecting fisheries central to Tribal diets, economies, and ceremonies. Roads "can fragment wildlife corridors, reducing populations of game species," which the DEIS says "diminishes hunting opportunities and violates the spirit of reserved hunting rights." Roads also act as vectors for invasive plant species that "can outcompete culturally significant native plants used for food, medicine, and ceremony." Timber harvest can alter "cultural forestscapes" that Tribes manage for specific species such as beargrass or huckleberries, and can remove trees "considered spiritually sentient or essential for ceremonial materials."

Construction and harvest activity "increase the risk of disturbance, looting, or destruction of archaeological and cultural sites, especially in the absence of robust monitoring and protection protocols." The "sensory impacts of machinery and increased human presence can disrupt ceremonial practices, wildlife behavior, and the spiritual character of sacred landscapes." The DEIS also warns that "projects that fail to integrate Indigenous knowledge into planning and design risk overlooking cultural sensitivities, ecological insights, and sustainable practices that could mitigate disturbance."

The conclusion states there would be "the greatest potential for adverse effects under alternative 2 and slightly reduced potential under alternative 3." Tribes' shared concerns span both tangible resources (access routes, water, plant and animal life) and intangible ones ("sense of place," spiritual and religious identity, opportunities for solitude and continued ceremonies). Under all alternatives, "future projects that propose activities currently prohibited by the roadless rule would require early and regular consultation with Tribes."

The document reports that "the Forest Service received 64 requests for consultation, 29 consultations have been held, and an additional 5 scheduled," and that the agency "began notifications to Tribes in July 2025."

The document states that "ANILCA subsistence hearings were conducted for the DEIS and proposed rule, consistent with Section 810 in 2019."

Per a footnote in the document (footnote 74, as cited by reviewers), pending Alaska Native Claims Settlement Act (ANCSA) land-conveyance legislation would affect up to 115,000 acres of National Forest System land, with roughly half falling within the 2001 Roadless Rule inventory.

For the Tongass National Forest, the document states that Alternative 3 "would have the same results as reinstating the 2020 Alaska Roadless Rule" and that Tongass-specific effects "are fully disclosed in the 2020 FEIS for the Alaska Roadless Rule and associated record. These findings are incorporated by reference."

More than 95 percent of inventoried roadless area (IRA) acreage outside Colorado and Idaho sits in ten Western states. The document tracks 397 "IRA footprint counties" nationwide. Their combined population grew 10.6 percent from 2010 to 2024 (55.1 million to 60.9 million people) — faster than the 9.7 percent national growth rate over the same period — with the fastest growth in the Intermountain, Pacific Northwest, and Great Plains regions. Almost half of these counties (191 of 397) are classified as rural.

Using a published research framework (Frey et al. 2022), the agency classifies counties as environmentally, economically, or socially forest-dependent based on set thresholds — for example, 75 percent forest land for the environmental criterion, or 10 percent of workers (or 15 percent of earnings) in forest-sector jobs for the economic criterion. By this method, 158 of the 397 IRA footprint counties (39.8 percent) are forest-dependent by at least one measure, and 21 counties (5.3 percent) meet the economic-dependence threshold specifically. Nearly 80 percent of the economically dependent counties are rural, and forest dependency varies sharply by region — for instance, over 90 percent of Northeast IRA-footprint counties qualify as environmentally forest-dependent, while none in the Great Plains meet any of the three thresholds.

"Since 1980, the amount of timber sold from the NFS has declined by more than 80 percent," driven by policy shifts, market changes, and litigation. Harvest peaked at 12.7 billion board feet in 1987, fell to a low of 1.7 billion board feet by 2002 (largely from Pacific Northwest and Pacific Southwest declines), and has averaged about 2.5 billion board feet over the last 15 years — 2.9 billion board feet in 2023, worth about $163 million. Overall timber-sector employment has fallen 30.5 percent since 2001, with the steepest losses in paper manufacturing (-37.3 percent) and forestry/logging (-33.1 percent). One category bucks the trend: employment in forestry support services — the stewardship-contracting and thinning jobs tied to restoration work — has grown 25.5 percent.

In 2023, timber harvest and processing from NFS lands contributed about $5.8 billion to U.S. GDP and supported roughly 51,200 jobs. Energy and mineral production from NFS lands contributed more than $7.6 billion to GDP and supported about 37,800 jobs the same year. Eleven large mines on NFS lands generated an estimated $1.4 billion in revenue in 2024. Currently 3.4 million acres of NFS land are leased for oil, gas, coal, and other leasable minerals; in 2024 that production was valued at over $4.8 billion and generated $533 million in Treasury royalties ($106 million from coal, $402 million from oil and gas, $25 million from other commodities).

Outdoor recreation is described as a major economic force: it supported about $639 billion of U.S. GDP (2.3 percent of the total) in expenditure and equipment spending — a larger GDP share than mining (1.5 percent) or utilities (1.6 percent). The Forest Service's 193 million acres received about 164 million recreation visits in FY2024. Visitors spent more than $13.4 billion in surrounding economies in FY2023, contributing $16.2 billion to GDP and supporting about 167,000 jobs. Wildlife-related visits alone (fishing, hunting, viewing wildlife) totaled 16.9 million in FY2023, with $1.2 billion in visitor spending, $1.4 billion in GDP contribution, and 14,600 supported jobs.

Because visitation to IRAs specifically isn't tracked, the agency estimates it indirectly: in 2024, visitors to the national forests and grasslands potentially affected by the rescission spent $8.5 billion in local communities, including $2.2 billion from trail-based and dispersed recreation and $753 million from hunting, fishing, and wildlife viewing in non-wilderness dispersed areas. Potentially affected IRAs make up about 31 percent of the non-wilderness NFS land in those forests; applying that share yields an estimated $886 million in visitor spending tied to IRA recreation specifically — a figure the DEIS says compares well with an independent 2018 academic estimate of about $605 million for 2017. Using a similar approach, the DEIS estimates $15 billion in total recreation "economic benefit" (consumer surplus) across the affected forests, of which roughly $1.9 billion is attributable to the potentially affected IRAs.

Under the current 2001 Rule, national NFS timber harvest could still rise by an estimated 25 percent, but harvest from IRAs themselves would not increase — meaning "there would continue to be no revenue, or benefits to the timber industry, from timber harvest in inventoried roadless areas." Existing mineral leases and locatable-mineral activity continue unchanged; new leases in IRAs still carry "no surface occupancy" restrictions. Recreation opportunities in IRAs would see little near-term change, though the DEIS notes a long-term risk: trails and access could deteriorate if the agency can't complete maintenance in areas that remain hard to reach. Non-commodity and social values tied to roadless character are conserved.

By removing roadless-area prohibitions rulewide, this alternative "would provide the greatest opportunity for an increase in annual timber harvest and revenue for the timber industry and an economic benefit loss to recreationists." It estimates $5.2–11.4 million per year in additional agency timber revenue, potentially a 5–10 percent nationwide increase in sawtimber harvest. On recreation, the DEIS estimates upper-bound annual losses of about $7 million in trail/dispersed-recreation spending and $2 million in wildlife-related spending, plus up to $4.8 million and $1.3 million respectively in lost recreation "economic benefit" — concentrated in the roughly 32 percent of IRA acreage the agency judges operable for harvest. On minerals, no net change in domestic leasable-mineral production is expected because oil, gas, and coal output depend on global markets; locatable-mineral development is unaffected because road access there is already a statutory right. The document adds that new roads could expand wildfire-fuels treatment options, but cautions the actual gain "would be modest" given road-building costs and declining maintenance budgets. Listed possible losses to people who value roadless character include diminished air and water quality, degraded scenic quality, reduced solitude, altered "special places," a diminished legacy for future generations, and "a threat to existence values."

This alternative removes 2001 Rule prohibitions only within a half-mile of existing roads or within the wildland-urban interface (WUI), keeping the roadless prohibitions in place elsewhere. It estimates $4.2–9.7 million per year in agency revenue and a 4–9 percent national sawtimber harvest increase — "some opportunity for an increase," but less than Alternative 2. Recreation losses would be smaller and easier to absorb, the DEIS says, because more undisturbed roadless acreage would remain available to receive displaced visitors. Fuels-management effects are described as similar to Alternative 2, since new road-based treatment would be concentrated near the communities it is meant to protect.

About 9.8 million acres (24.4 percent) of potentially affected IRAs overlap the statutory WUI definition. Fuel-treatment costs generally range from $100 to $500 per acre, reaching $2,000 or more per acre in high-value or complex areas; the agency's national fuels budget exceeds $400 million annually, treating over 3 million acres a year. Restoration and fuels work is described as returning more than seven dollars in benefit per dollar invested in high-risk, high-value watersheds, based on one cited study. Under both action alternatives, new road access could expand mechanical treatment options in the WUI, but the DEIS states plainly that "the high cost of road building and declining budgets for road construction and maintenance mean the overall increase in treatment capacity would be modest."

The document lists social values tied to roadless land — ecosystem health, species and water-quality conservation, scenic quality, solitude, sense of place, legacy for future generations, and "existence values" (valuing that an area remains undeveloped, independent of ever visiting it). Under Alternative 2, it projects these values could be diminished through reduced air and water quality, degraded scenery, less solitude, and altered "special places." Alternative 1 and the untouched portions of Alternative 3 conserve these values.

The conclusion states that Alternative 2 "enhances the quality of life for people that value timber harvest and potential mineral and energy development," and that both action alternatives "similarly enhance the quality of life for people living in communities near the IRAs" through added wildfire-risk-mitigation opportunity. It states Alternative 2 "would have the greatest negative effects to those who primarily use recreation opportunities located within IRAs, businesses and communities that depend on the spending of recreationists using IRAs, and those that hold intrinsic value for the existence of roadless areas."

The agency traces special treatment of the Tongass back to 2001, when USDA determined it "deserved 'special attention in formulating alternatives due to its unique social and economic conditions,'" explaining that it had "considered the alternatives of exempting and not exempting the Tongass National Forest" and sought "to balance the extraordinary ecological values of the Tongass National Forest against the needs of the local forest dependent communities in Southeast Alaska" (66 FR 3254). The 2020 Alaska Roadless Rule Final EIS found "similar issues drove the Alaska-specific state rulemaking." The current DEIS gives three reasons for treating the Tongass separately here too: it is "a unique environment relative to other IRAs," it "includes a large proportion of IRAs (approximately 9.3 million acres, nearly 1/4 of the potentially affected inventoried roadless area acreage)," and it "has a long history of special treatment in roadless rulemaking."

The document states plainly that "the effects associated with the potentially affected IRAs within the Tongass National Forest are fully disclosed in the 2020 FEIS for the Alaska Roadless Rule, analysis supporting the 2023 rulemaking, and associated record," and that "this EIS uses those analyses as outlined in 7 CFR 1b.9 on efficient and effective environmental reviews." It draws an explicit contrast: "the environmental impacts presented in the other sections of the DEIS are programmatic and nationwide in nature," while "the 2020 FEIS provides more specific, localized effects analysis for the Tongass National Forest affected environment, which supplement the broader nation-wide analysis." What follows is described as "a summary of effects from the 2020 FEIS," with "only the conclusions related to the potentially significant impacts... summarized here."

Of the six alternatives analyzed in the 2020 FEIS, "Alternative 1 analyzed no action in which the 2001 Roadless Rule would remain in place for Tongass IRAs" — "the same as alternative 1/no-action alternative for this DEIS because the 2001 Roadless Rule is currently in effect for the Tongass." "Alternative 6 of the 2020 FEIS analyzed a full exemption from the 2001 Roadless Rule for the Tongass," which "would have the same effects as alternatives 2 and 3 for this DEIS." To avoid confusion, the DEIS says it will simply refer to "2001 Roadless Rule in place" and "removing roadless rule prohibitions."

"The amount of new road construction would be similar under all alternatives," though removing the Roadless Rule "would have slightly more road miles" — an estimated 49 more miles of potential new road construction compared to leaving the rule in place. Average road density for all NFS lands works out the same either way (0.23 miles/sq. mile). But removing the prohibitions "on all 9.3 million acres of roadless areas would allow the maximum level of road construction for timber harvest and all other uses." The DEIS adds that "the economics of building roads to access forest land farther from the forest transportation system would be a limiting factor for new road construction."

"The PTSQ [Projected Timber Sale Quantity] for the 2016 Forest Plan would not change under any of the alternatives," and "the main effect of removing the Roadless Rule on timber resources would be the ability to develop economic sales" over "a greater area." With the Roadless Rule in place, about 564,000 acres (227,000 old growth, 334,000 young growth) are mapped as suitable for timber production; with it removed and the associated Forest Plan suitability change, about 749,000 acres (395,000 old growth, 354,000 young growth) would be suitable — a net gain of about 168,000 acres of suitable old growth (including 59,000 acres of high-volume old growth) and about 20,000 acres of suitable young growth. Actual harvest levels are projected to stay close either way: about 42,500 acres of old growth and 284,000 acres of young growth over 100 years under both scenarios.

Timber harvest in productive old growth "may reduce biological diversity by shifting the age-structure of the forest... changing the composition of understory vegetation, and removing key habitat features such as large decadent trees, snags, and downed logs." With the Roadless Rule removed, "roads and timber harvest are likely to penetrate much farther into roadless areas, resulting in a greater degree of fragmentation," and effects on wildlife and the Old-growth Habitat Conservation Strategy are "expected to be relatively low but greater than projected for the no-action alternative." On carbon, harvest effects are described as "similar and minor whether the Roadless Rule is in place or not," affecting an estimated 3.5 percent of the Tongass's 9.7 million forested acres, 6 percent of productive forest land, and less than 1 percent of productive old growth over 100 years.

Removing the Roadless Rule "would have a slightly larger potential for adverse effects to physical resources... because it is anticipated that there would be slightly more road development," though the differences "would be minor" given best management practices and Forest Plan standards, with most disturbed soil rehabilitated after projects. Average road density is about 0.19 miles per square mile with the rule in place, rising to an anticipated 0.23 with it removed — translating to "about 90 percent of all subwatersheds" remaining in the "properly functioning" range (under 1 mile of road per square mile). On fish, "roads pose the greatest risk to fish resources on the Tongass," but overall effects to fish habitat are "expected to be minimal whether the Roadless Rule is in place or not," given Forest Plan riparian protections; any site-specific effects would be addressed in separate, later project-level NEPA review.

"All Endangered Species Act listed species are associated with the offshore marine environment adjacent to the National Forest"; there are no listed threatened or endangered species occupying the terrestrial or aquatic ecosystems the Tongass manages, "except for a few isolated haul-out locations for the Stellar sea lions." The review "found to have 'no effect' to any threatened or endangered species or designated critical habitat," so no consultation with the Fish and Wildlife Service or National Marine Fisheries Service was needed. NMFS separately concluded the 2016 Tongass Forest Plan Amendment EIS was "not likely to adversely affect" listed species. No federally listed fish species or stocks originate from Alaska streams, and no fish species are currently designated sensitive in the Alaska Region.

Under the 2001 Roadless Rule, most projected harvest occurs in settings where "some modification of the natural environment is expected," and less than 1 percent of acres in Primitive, Semi-Primitive Non-Motorized, and Semi-Primitive Motorized settings would be harvested after 100 years even at maximum allowable levels. With roadless prohibitions removed, "recreational visitors with an expectation of a remote experience would be most affected," and Semi-Primitive Non-Motorized acres would rise to 18 percent of the estimated total potential timber harvest. Nearly all new roads would be closed following harvest — unavailable to highway or high-clearance vehicles, though possibly accessible by other means — so "any potential increase in recreation access may be limited by road closures." Outfitter and guide operations, which already face some potential conflict with harvest under the current rule, would see "an increased potential for impacts... by increasing the number and geographic extent of the acres affected."

No changes to Scenic Integrity Objectives are proposed, and old-growth harvest would continue to follow the 2016 Forest Plan's objectives. Even so, "removing the Roadless Rule would have the highest effects on scenery in most viewsheds," due to more road development reaching remote places — though the document adds "there is not a big difference in the amount of estimated road mileage whether the Roadless Rule is in place or not." Viewsheds with the highest potential for negative effects from young-growth harvest include Chatham Strait, Duncan Canal, Frederick Sound, Lynn Canal, and Stikine Strait; from old-growth harvest, Duncan Canal, Eastern Passage, Frederick Sound, Stikine Strait, Tenakee Inlet to Tenakee Springs, and Zimovia Strait.

Removal carries "an increased risk to cultural resources... because of potentially greater road lengths" and from activity in areas "currently and previously protected from development and harvest activities." The Tongass, "with nearly 17 million acres of largely undeveloped land, includes extensive subsistence resources" that form "the foundation for Native culture." Timber cutting is prohibited in inventoried roadless areas under the rule, with limited exceptions (66 FR 3244 § 294.13) including providing trees to tribes free of charge for cultural purposes — an exception that "would remain in place with the Roadless Rule removed." Removing the rule "would not require specific exceptions for access" and would create "the opportunity for an increase in timber harvest in some places," but access "may increase competition with the timber industry for trees to be used for traditional or cultural purposes," and the DEIS states plainly: "competition is the greater concern from the Tribes." It concludes that "the type of access allowed with the Roadless Rule in place is preferable to Tribes compared to the access created by removing the Roadless Rule."

Section 810 of ANILCA (16 U.S.C. 3120) requires evaluating effects of certain federal land actions on subsistence uses — abundance and distribution, access, and competition — and, where a "significant restriction" of subsistence uses would result, requires notice, hearings, and specific findings. The DEIS's own legal position is that "an ANILCA Section 810... evaluation and determination is not required for approval of the proposed rule," because it is "a rulemaking process and a programmatic level decision," not a decision to "withdraw, reserve, lease, or otherwise permit the use, occupancy, or disposition" of forest land. It notes the 2020 Alaska Roadless Rule FEIS conducted its own subsistence evaluation covering these factors.

"The proportion of timber harvest occurring in roadless areas would vary with the Roadless Rule in place or not, but overall regional economic impacts are assumed to remain constant." Based on the 2016 Forest Plan Amendment EIS, with an estimated annual average harvest of 46 MMBF, all alternatives would support an estimated 92 jobs in logging, 49 to 100 jobs in sawmilling, and 29 to 46 jobs in transportation and other services, with direct income of $9.8 million to $10.4 million. Separately, subsistence harvest of fish and wildlife "takes on special importance" in Southeast Alaska's seasonal, resource-based economy, "supplementing cash incomes" where wage opportunities are limited, and "removing the Roadless Rule could have impacts on the amount and distribution of subsistence resources."

The document is explicit about the split in method: "the environmental impacts presented in the other sections of the DEIS are programmatic and nationwide in nature," while the Tongass gets "more specific, localized effects analysis" drawn from the 2020 FEIS.

The Tongass-specific figures repeated throughout this chapter — 9.3 million acres, "nearly 1/4 of the potentially affected inventoried roadless area acreage," "about 56 percent of the Forest" — are presented as established facts anchoring the whole chapter's analysis.

The Department published a Notice of Intent (NOI) to prepare this EIS on August 29, 2025, opening a 21-day comment period under 7 CFR 1.7(b). Over 220,000 comment letters came in — from Tribes and Alaska Native Corporations, members of Congress, other governments, businesses, organizations, and individuals — and counting every petition signature as a separate submission, the total reaches over 625,000. Of the letters received, "approximately 99 percent were generally opposed to the proposed rule recission, while approximately 1 percent were generally in support." The agency says it reviewed, coded, and analyzed all NOI comments and responded by modifying the proposed action, using information to inform the analysis, making factual corrections, or considering but making no change where a concern was outside the rulemaking's scope or the agency's authority.

The original NOI described just two options: full rescission of the 2001 Roadless Rule (the proposed action) and retaining the rule (no action). Commenters asked for a broader range, and the appendix catalogs what they proposed — a strengthened rule with fewer exceptions, a no-net-roads policy, boundary modifications that exclude already-roaded land, region- or state-specific rules modeled on Idaho and Colorado, and several hybrid "modified rule" concepts for targeted, time-bounded access. The DEIS states that "the six alternatives represented the spectrum of management regimes identified to the Forest Service," and that it evaluated alternatives "not considered in detail" with a brief rationale for each.

The stated Purpose and Need is "a need to increase local management flexibility and, where necessary, allow for active management to respond to changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface." Commenters raised concerns that this justification was inadequately supported, noting the existing rule already allows exceptions for fire suppression, fuel reduction, and habitat improvement, and questioning the scientific basis for rescission given long-term monitoring commenters say supports retaining the rule. The DEIS states it made only "minor clarifications to the purpose and need" in response.

The DEIS states that "The Forest Service received 64 requests for consultation, 29 consultations have been held, and an additional 5 scheduled." Compliance with Executive Order 13175 (tribal consultation and coordination) and Executive Order 13007 (Indian sacred sites) is mapped in Table 52 to the "Consultation with Federally Recognized Tribes and Alaska Native Corporations" and "Tribal Rights and Interests" sections of the document. Commenters raised concerns about rescission's effects on Indigenous rights, cultural heritage, and subsistence practices, and asked for meaningful, early government-to-government consultation.

The document states that "ANILCA subsistence hearings were conducted for the DEIS and proposed rule, consistent with Section 810 in 2019," referring to the Alaska National Interest Lands Conservation Act's subsistence-protection provisions.

For the Tongass National Forest, the document states that Alternatives 2 and 3 "propose the same action, relative to the inventoried roadless areas on the Tongass National Forest, as the 2020 Alaska Roadless Rule," and that "the previous analyses were reviewed and are still relevant (see Appendix 4 – Review of the Final Environmental Impact Statement for the 2020 Alaska Roadless Rule)." The DEIS states elsewhere that it "relies on and incorporates by reference the 2020 Final Environmental Impact Statement (2020 FEIS)... and associated records." Appendix 4 also states that "roadless management on the Tongass National Forest has been consistent with the 2001 Roadless Rule for over a decade."

Table 51 and Table 52 map the statutes and executive orders the agency says are addressed elsewhere in the document — the National Forest Management Act, Clean Water Act, Clean Air Act, Endangered Species Act, National Historic Preservation Act, and designated-areas requirements, plus a set of executive orders on tribal consultation, invasive species, migratory birds, hunting heritage, and energy/timber/mineral production. The document states that "compliance with applicable laws or regulations and executive orders are documented in the sections as noted... below," and that final compliance "determinations" will appear in the FEIS and Final Rule.

The DEIS discloses that, "based on preliminary draft biological assessment," the action would result in a "may affect, and is likely to adversely affect" determination for 327 ESA-listed species and 71 critical habitats, with effects under Alternative 3 described as "similar or reduced" relative to Alternative 2. The document also states that "effects to the species were determined to be highly impactful" and that "[w]here information is lacking the Forest Service erred on the side of making the more impactful determination."

The Purpose and Need section states the agency "prioritizes decisionmaking by local Forest Service officials informed by Tribes, State, and local communities." The socioeconomic discussion documents "starkly divergent impacts" between resource-dependent rural communities facing "job losses, mill closures and economic instability" and recreation-dependent "gateway communities." Table 52's list of applicable executive orders does not include an environmental-justice entry.

Per the document's procedural history, on June 23, 2025, the Secretary of Agriculture "publicly announced the intent to rescind the 2001 Roadless Rule" — roughly two months before the NOI opened the EIS comment period on August 29, 2025.

The document is supported by an extensive references list — hundreds of peer-reviewed studies, Forest Service technical reports, and government datasets covering fire, soils, wildlife, hydrology, and forest economics — and the agency states throughout that specific figures (acreages, percentages, dollar amounts) are drawn from this literature and from its own inventory and monitoring data.