We, the undersigned, oppose the proposed rescission of the 2001 Roadless Rule, and ask the Department to select Alternative 1 (No Action). By the Department's own numbers, rescission offers small, uncertain gains, carries real costs for taxpayers and local economies, and rests on an incomplete record.

1. The Department's own analysis shows modest benefits. The Department identifies approximately 4.8 million acres where existing forest plans and operating conditions could allow expanded timber management. Under its conditional harvest scenario, which it considers unlikely, annual National Forest System sawtimber harvest could increase by 5 to 10 percent, generating an estimated $5.2 million to $11.4 million annually in Treasury and Forest Service revenue [1]; however, it also predicts millions of dollars in road costs [2] and estimates annual losses to recreationists of about $6.1 million.[1] Those losses should be evaluated using a consistent economic framework that distinguishes government receipts, private revenues, and changes in public welfare. On energy, the Department anticipates no net change in domestic oil, gas, or coal production, and no change for locatable minerals, where access rights exist regardless of the Rule.[1]
The possibility of additional timber revenue does not, by itself, demonstrate that rescission would deliver a net public benefit. The Department should establish whether the anticipated benefits justify the associated public costs and environmental effects.

2. Rescission exposes taxpayers to road costs the agency cannot fund. The Forest Service reports a $6.9 billion deferred-maintenance backlog for roads and bridges, and the Department concedes that this would limit any efficiency gains.[1] According to roadless.org’s excerpts of the Draft EIS, general construction benchmarks range from approximately $80,000 to $100,000 per mile for native-surface roads and $1 million to $2 million per lane-mile for asphalt, with difficult roadless terrain potentially increasing costs substantially,[2] and it concludes that deferred maintenance and management costs are likely to rise under Alternatives 2 and 3.[3] These benchmarks do not establish the total cost of rescission. The Department should estimate additional road mileage under each alternative and disclose construction, maintenance, and decommissioning costs, identifying who would bear them.

3. The wildfire rationale does not match the Department's own data. The Draft EIS reports that wildfire ignitions are less frequent and less dense in roadless areas than on other national forest lands, and that more public road access could increase human-caused ignitions.[3] Peer-reviewed research found a wildfire ignition density of 7.99 fires per 1,000 hectares within 50 meters of roads, compared with 1.97 in inventoried roadless areas [5]. These findings warrant an explicit assessment of the tradeoff between suppression access and additional ignition risk, rather than an assumption that expanded road access necessarily improves wildfire outcomes.

The 2001 Rule already permits qualifying removal of generally small-diameter timber to reduce uncharacteristic wildfire effects, subject to ecological conditions. It also permits maintenance of existing classified roads[4]. New road construction and reconstruction remain subject to separate, limited exceptions, including protection of life or property from an imminent fire threat. Before rescinding the Rule, the Department should explain which necessary treatments cannot proceed under these authorities and why.

4. Reliance interests and regulatory certainty. The proposed rule invites comment on reliance interests. After 25 years, many parties have organized their affairs around the Rule: municipal water systems drawing from the 354 watersheds that include roadless areas;[4] outfitters, guides, and gateway-town businesses, given that visitors to the affected national forests spent $8.5 billion in local communities in 2024 and forests containing roadless areas receive about 125 million visits a year;[3] and local governments and landowners who have planned around stable land-use rules. In reconsidering this longstanding policy, the Department must assess significant reliance interests and weigh them against its reasons for changing course. It should examine whether municipal water providers, recreation businesses, local governments, and landowners have made investments or planning decisions based on the Rule. The final decision should explain how those interests were evaluated and whether alternatives or mitigation could address potential disruption.
Rescission would also not reduce regulatory burden. Rescission would remove national prohibitions, but future projects would still be subject to applicable environmental review and consultation requirements under NEPA and the Endangered Species Act. The Draft EIS identifies more than 300 threatened, endangered, or proposed species in the affected areas,[3] and, as described in the Draft EIS, the preliminary draft biological assessment finds the proposal likely to adversely affect 327 listed species.[2] The Department should substantiate its claimed administrative savings and account for the planning, environmental analysis, and consultation required for additional projects enabled by rescission.

5. The process should match the stakes. The Department has designated this rule economically significant under Executive Order 12866,[1] yet the public originally had 32 days to comment on the proposed rule and Draft EIS, since extended by 15 days to October

6.[6][7] The 2005 attempt to replace the Rule had 120 days for comment on the proposed rule,[7] and the original rulemaking included over 600 public meetings and generated more than 1.6 million comments[8].

The proposed rule reports 64 Tribal requests for consultation and 29 consultations held, and that most Tribal governments consulted oppose rescission.[1] The Forest Service has scheduled Alaska subsistence hearings, including an additional hearing in Craig on October 26, after the October 6 written-comment deadline. The Department should extend the written-comment period to allow meaningful consideration of testimony from all subsistence hearings.

Finally, the Department's scoping round for the current rescission effort drew more than 220,000 comment letters representing over 625,000 individuals and organizations[1]; separately, roadless.org reports that its analysis found more than 99 percent of submitters opposed rescission[8]. A national survey of likely voters commissioned by The Pew Charitable Trusts and conducted by Susquehanna Polling and Research in December 2025, found that 76 percent supported the Roadless Rule. In a separate question, 71 percent of Republicans prioritized conservation over opening more lands to timber harvesting or mining. Across all respondents, 11 percent selected expanded harvesting or mining as the priority. [4]

Requests. We respectfully ask the Department to take the following actions:
Select Alternative 1 (No Action) and withdraw the proposed rule.

If the Department's concern is fuels near communities, direct forest supervisors in writing on use of the Rule's existing exceptions, with training and resources, rather than rescinding the national standard.[4]

Extend the comment period to at least 120 days and hold in-person public meetings in the regions most affected.

Before making a final decision, the Department should provide a transparent comparison of alternatives that identifies projected road mileage, associated costs and funding sources, quantified and unquantified benefits, and relevant reliance interests. It should also explain the definitions, exclusions, and overlaps underlying its acreage estimates so the public can understand which lands would change under each alternative.

Thank you for considering these comments.

Sources cited
[1] USDA, Proposed Rule, Special Areas; Roadless Area Conservation, 91 Fed. Reg. 53827 (Aug. 20, 2026): https://www.federalregister.gov/d/2026-16965
[2] roadless.org, "The DEIS in Plain English" (annotated excerpts of the USDA Draft EIS): https://roadless.org/deis-explained
[3] Backcountry Hunters & Anglers, "Roadless Rule: A Closer Look at the Record" (Aug. 28, 2026) (quoting USDA Draft EIS pp. 24, 50, 133, 163, 212): https://www.backcountryhunters.org/news/details/roadless-rule-a-closer-look-at-the-record
[4] The Pew Charitable Trusts, "An Update on the 'Roadless Rule'" (Feb. 18, 2026): https://www.pew.org/en/research-and-analysis/articles/2026/02/18/an-update-on-the-roadless-rule
[5] Aplet, Hartger & Dietz, Fire Ecology 22:8 (2026): https://doi.org/10.1186/s42408-026-00450-2
[6] USDA, Extension of Comment Period (Sept. 11, 2026): https://www.federalregister.gov/d/2026-18648
[7] Earthjustice, "Groups Request Public Comment Period Extension for the Proposed Rollback of the Roadless Rule": https://earthjustice.org/press/2026/groups-request-public-comment-period-extension-for-the-proposed-rollback-of-the-roadless-rule
[8] roadless.org, Key Facts: https://roadless.org/key-facts