Comment Analysis Overview

***Please see attached files*** To whom it may concern: Thank you for providing this opportunity to comment on the scoping for “Special Areas; Roadless Area Conservation; National Forest System Lands,” docket number FS-2025-0001. The attached comments are signed and endorsed by the following organizations: 350 Central Mass, 350 Mass, Adirondack Council, Biofuelwatch, Boston Catholic Climate Movement, Canton Residents for a Sustainable Equitable Future, Climate and Democracy Project, Climate Communications Coalition, Climate Writers, Elders Climate Action - Massachusetts Chapter, Friends of Bell Smith Springs, Friends of Blackwater Inc, Greenfield Solar, Hilltown Vision, Keep the Woods, Kucinich Institute for Human and Ecological Security, MASS PLAN, North American Climate, Conservation and Environment (NACCE), Partnership for Policy Integrity, Pipe Line Awareness Network for the Northeast, Ridgeview Conservancy, Slingshot, Soda Mountain Wilderness Council, Speak For The Trees Too WV, Standing Trees, Tennessee Heartwood, Third Act Massachusetts, Trees as a Public Good Network, Wendell State Forest Alliance, Wild Hope, Worcester Congregations for Climate and Environmental Justice, Peace of Mind Reiki, Mountain Sense LLC., Massachusetts Forest Watch, North Country Alliance for Balanced Change, Standing Trees, Third Act Vermont, Stop Vermont Biomass, Wonalancet Out Door Club. On behalf of our thousands of supporters and members, we strongly oppose rescinding the 2001 Roadless Area Conservation Rule (Roadless Rule, Rule, or RACR). Instead, we urge you to 1) keep the Rule intact to protect the wildest and healthiest parts of our National Forests, and 2) update the Roadless Rule maps to include additional areas that have been mapped as IRAs during Forest Plan revisions since 2001. Finally, we request an extension of the current comment period and assurances that any future comment periods will extend longer than just three weeks, which is an insufficient amount of time to facilitate robust public participation. Thank you for your careful consideration of our comments. I will submit cited documents as attachments in follow-up comment submissions. Zack Porter Executive Director Standing Trees

Oklahoma construction worker and family opposing Roadless Rule rescission - see attached detailed comment As blue-collar workers, my husband and I travel from Oklahoma to Arkansas' Ozark-St. Francis National Forest for affordable family vacations. The Illinois Bayou roadless area provides pristine recreation unavailable in Oklahoma due to private land fragmentation. Key Points: -Arkansas' $7.3B outdoor recreation economy and 68,000 jobs depend on intact forest landscapes -Working families from across the region (OK, TX, LA, MO, TN) travel specifically for roadless area experiences -Logging operations consistently damage Forest Service roads (including sole access to private homes) with zero accountability for repairs -Water quality degradation: pristine Ozark waters polluted by post-logging sediment and debris -As construction professionals, we operate under "if you break it, you fix it" - why doesn't timber industry? -DOGE-era fiscal responsibility demands avoiding new maintenance burdens from logging roads -Observed identical problems across Pike/Arapaho/Roosevelt (CO), Carson (NM), and Ouachita (OK/AR) forests Bottom line: Roadless protection preserves the scenic integrity and democratic access that drives Arkansas tourism success. Rescission will destroy exactly what attracts working families to spend thousands annually in Arkansas' economy. Full detailed comment with regional evidence attached.

​There is nothing more “wasteful” (to the complex atomic constructions that are, and IS, energy: That's everything we find of use, from potential in fuels to kinetic in the hybrids or artifacts we manufacture) than over-taxing resource sustainability. While coupled with this, there is nothing more "consistently" critical to human society’s consuming condition and is its divine directive (by which without volition we MUST abide) than the expedience of specie replication. That in mind, is it not imperative than we safeguard perpetuation of a sustainable, and civilized, socioeconomic platform upon which our offspring can optimize? Blind, profit-seeking ambition has a consequence exponentially multiplying with each ensuing moment in our culture, and with its ever-expanding requisite for resources and markets, the untethered rampant wielding of this 'blind' incentive does not entail the immediate cessation of disrupting any, and eventually all, currently intact biospheric ecosystems necessary to preserve the "untrammeled by man," Edenic bounty we currently enjoy, nary the garden given us (or rather taken for us) at the birth of our nation, and that cannot persist. As a federally entrusted service mandated to ensure perpetuation of our Commons, the last remaining, intact, arboreal rainforest is an endemic biospheric eco-subsystem with pandemic planetary ecosphere implications. As you further review its "Wilderness" designation, ensure that man "himself is a visitor who does not remain" (Howard Zahniser)! All Earths elements are interwoven, our consciousness included, and impact anywhere requires its maintenance. Individual participation by all in synthetic clean-up is elemental & essential!.

There is nothing more “wasteful” (to the complex atomic constructions that are, and IS, energy: That's everything we find of use, from potential in fuels to kinetic in the hybrids or artifacts we manufacture) than over-taxing resource sustainability. While coupled with this, there is nothing more "consistently" critical to human society’s consuming condition and is its divine directive (by which without volition we MUST abide) than the expedience of specie replication. That in mind, is it not imperative than we safeguard perpetuation of a sustainable, and civilized, socioeconomic platform upon which our offspring can optimize? Blind, profit-seeking ambition has a consequence exponentially multiplying with each ensuing moment in our culture, and with its ever-expanding requisite for resources and markets, the untethered rampant wielding of this 'blind' incentive does not entail the immediate cessation of disrupting any, and eventually all, currently intact biospheric ecosystems necessary to preserve the "untrammeled by man," Edenic bounty we currently enjoy, nary the garden given us (or rather taken for us) at the birth of our nation, and that cannot persist. As a federally entrusted service mandated to ensure perpetuation of our Commons, the last remaining, intact, arboreal rainforest is an endemic biospheric eco-subsystem with pandemic planetary ecosphere implications. As you further review its "Wilderness" designation, ensure that man "himself is a visitor who does not remain" (Howard Zahniser)!

Please see enclosed Technical Comment of Natural Resources Defense Council et al. with attachments, Part 1 of 10 - NRDC et al. Doc. Nos. 001–016, submitted on behalf of 350 Seattle, Advocates for Snake Preservation, Alaska Wilderness League, American Bird Conservancy, Badlands Conservation Alliance, Californians for Western Wilderness, CalWild, Cascade Forest Conservancy, Cascadia Wildlands, Center for Biological Diversity, Center for Large Landscape Conservation, Central Oregon LandWatch, Central Sierra Environmental Resource Center, Chattooga Conservancy, Citizens United for Responsible Energy &Development (CURED), Climate Communications Coalition, Conservation Northwest, Conservatives for Responsible Stewardship, Dave Willis, Defenders of Wildlife, Diné C.A.R.E., Earthjustice, Environment America, Environment Georgia, Environmental Defense Center, Environmental Law & Policy Center, Environmental Protection Information Center (EPIC), Friends of Doluglas-fir National Monument, Friends of the Clearwater, Friends of the Columbia Gorge, Friends of the Inyo, Friends of the Kalmiopsis, Friends of the Shasta River, Friends of the Wild Swan, Gallatin Wildlife Association, Glacier-Two Medicine Alliance, Grand Canyon Trust, Great Old Broads for Wilderness, Greater Hells Canyon Council, Greater Yellowstone Coalition, Heart of the Gila, Heartwood, High Country Conservation Advocates, Izaak Walton League Rapid City, South Dakota Chapter, Joey Smallwood, Klamath Forest Alliance, Klamath-Siskiyou, Wildlands Center, Los Padres ForestWatch, MCAT Mobilizing Climate Action,Together, Methow Valley Citizens Council, Mount Shasta Bioregional Ecology Center, National Parks Conservation Association, Natural Resources Defense Council, New Mexico Wild, Niel Lawrence, North American Climate, Conservation and Environment (NACCE), North, Cascades Conservation Council, Northeastern Minnesotans for Wilderness, Olympic Park Advocates, Oregon Wild, Pilchuck Audubon Society (WA State), Prairie Hills Audubon Society (of Western South Dakota), Quiet Use Coalition, Resource Renewal Institute, Rocky Mountain Wild, Santa Fe Forest Coalition, Save Our Canyons, Sheep Mountain Alliance, Sierra Club, Silvix Resources, Snowlands Network, Southern Environmental Law Center, Southern Utah Wilderness Alliance, Standing Trees, The Forest Advocate, The Wilderness Society, Umpqua Watersheds, Upper Gila Watershed Alliance, Upper Snake River Tribes Foundation, Western Environmental Law Center, Western Slope Conservation Center, Western Watersheds Project, Whatcom Million Trees Project, White Mountain Conservation League (WMCL), Wiconi un tipi, Wild Connections, Wild Hope, Wild Montana, Wild Watershed, WildEarth Guardians, Wilderness Watch, Wyoming Wilderness Association, Yaak Valley Forest Council.

Procedural Safeguards & Stakeholder Consultation The proposal to rescind the 2001 Roadless Rule should specify explicit requirements for Tribal, state, local, and public input after rescission, including whether notice and hearings will occur for individual projects previously protected under the Roadless rule, to guard against arbitrary disparity in implementation. Definition of “Road Construction” & “Timber Harvest” Activities The rule text should clarify whether the rescission excludes or retains restrictions on all road construction (temporary, seasonal, or permanent) and all forms of timber harvest (e.g., selective, clearcut, salvage), since ambiguity here can lead to unchecked logging or fragmentation; precise definitions are necessary. Environmental Impact & Baseline Protections The rescission text should require an updated baseline environmental assessment for each affected National Forest (including habitat, watersheds, carbon storage) and ensure protections for watersheds, endangered species habitat, biological corridors, and climate resilience, to ensure that the rollback does not lead to irreversible harm. Transitional Provisions & Grandfathering The rule should include transitional clauses for projects already planned, permitted, or in design phase under the 2001 rule protections (e.g., those that had already received environmental review), specifying whether they will retain protections or be subject to new standards. Monitoring and Enforcement The rescission should retain or establish enforceable reporting, transparency, and monitoring requirements to track road-building, logging, and other land disturbances in previously protected roadless areas; this includes periodic public reporting of acreage impacted, species effects, erosion/water quality impacts, and climate metrics. Climate, Ecosystem, and Equity Impact Considerations Since roadless areas contribute disproportionately to carbon sequestration, biodiversity, water regulation, and local community livelihoods, the rule should require quantified analysis of equity impacts—e.g. Indigenous communities, rural populations—and climate impacts (carbon emissions, loss of resilience) before finalization, and integrate those metrics into decision-making thresholds.

LEAVE the Tongass et.al. National Forests, ROADLESS !! Though the Climate Crisis may have been precipitated by unjust economics, it affects everything, even the way we imagine reality. This fossil fuel emollition, causing greenhouse gas clouded skies and acidified oceans of public waste, not being factored into the profit maximizing scheme of business law (our Constitutional laws contemporary derivation), is throwing the Planet's ecological system into schizophrenia and scientifically "J-curving" humanity (and all higher-order organics mandatory to the civilized human organization we enjoy) to a specie genocide, all as a result of our mischaracterizing resource consumption and depletion. This warlord ensuing mindset promotes the demagoguery of Dunleavy, Trump, et.al. viciously seeking self-preservation at any cost, all because of poor planning or governance of our resources Just a few days ago, the Birch Glacier outside Blatten, Switzerland collapsed wherein the ensuing landslides and floods provoked and bequeathed at least 10 human m fatalities while injuring 100's! Prevention and preparation for Glacier Bay and the 100's if not 1000's of settlements near ice floes in Alaska must be implemented. Revocation of the Clean Energy tax credits, nor deamination of the human health element with Medicaid, Medicare, the ACA or Social Security detraction touted in H.R. 1, must be refused! It's all about energy balance around the Globe, meaning wasted energy needs to be constrained in high energy concentrated areas! Unhuman psycho-schizophrenics ...walking dead are these inhuman zombie-oligarchs!!! Mis-using the energy we have available to help us survive on Earth! Maybe only I can see that ANY and ALL "energy" is found in "complex atomic construction," which is the real 'value' of any- and everything, from constructing microchips and plastic nanobeads to the atomic bonds in germs, gems, and in intellectual effort (or political WILL/power) and in its exchange in diplomacy, must not be WASTED! "Education" is best to help others understand this relation, but only if and when that education is objective and sufficient. Then, ALL we need to do individually is "WASTE the least we possibly can," publicly and privately, to nearly all existential discord we have assumed.

As a federally-recognized American Indian Tribal nation whose political existence precedes the United States of America by millennia, the Pueblo de Cochiti's sovereignty does not dissipate or dissolve at the whims of a federal agency rule-making process. In fact, any such action must not dismiss the historical, social, cultural, and spiritual relationships which Pueblos, Tribes, and Nations have maintained with the New Mexico homelands well before the arrival of Spanish colonialism, Mexican nationhood, and/or the US invasion in 1846. Indeed, unlike many American Indian nations, the Pueblo de Cochiti has remained where it has always been--albeit its land base now drastically reduced due to state-sponsored disenfranchisement and dispossession across three settler-sovereigns. As the Tribal Historic Preservation Office (THPO) with the Pueblo de Cochiti, it is this Office's duty to speak truth to power and remind the US settler state of these Indigenously distinct truths. It is both disappointing and unsurprising that governments across the US settler state paradigm do not hold themselves to international human rights legal standards and doctrines of Free, Prior, and Informed Consent (FPIC) as specified in article 19 of the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), namely: "States shall consult and cooperate in good faith with the indigenous peoples concerned through their own representative institutions in order to obtain their free, prior and informed consent before adopting and implementing legislative or administrative measures that may affect them." This proposed rescission of the USDA's "Roadless Rule" constitutes an administrative measure that directly affects the Pueblo de Cochiti in more ways than what the space of a public comment can possibly communicate. Yet, it cannot be overstated the kind of negative impact that this proposed rescission will have on the Pueblo de Cochiti and its traditional homelands now located within what is now known as Santa Fe National Forest, alongside those national forests within which the traditional homelands of sister Pueblos, Tribes, and Nations are located. As the Advisory Council on Historic Preservation notes in their 2024 Policy Statement on Indigenous Knowledge and Historic Preservation, there is indeed an "interdependent relationship between people and place, sacred sites and historic properties, including properties of religious and cultural importance to Indian Tribes, Native Hawaiians, and other Indigenous Peoples, [which] exist throughout the United States and its territories and jurisdictions." Such relationships comprise irreplaceable fabrics comprising the vibrant tapestry of Cochiti social, cultural, ecological, and spiritual life. In these ways, the Pueblo de Cochiti THPO must vehemently oppose this proposed rule and insist that any such action directly impacting Cochiti lands and/or cultural resources be accountable to the government-to-government responsibilities and consultation obligation of the US settler state. Anything less comprises willful disregard and disrespect for the sovereignty, self-determination, and peoplehood of the Pueblo de Cochiti. Gregorio Gonzales, Ph.D. (Comanche & Genízaro) Tribal Historic Preservation Officer Pueblo de Cochiti

To the Reviewing Officer, Protect the Wilderness Areas of the White Mountain National Forest. The Wilderness Areas (the Pemigewasset, Great Gulf, Wild River, Sandwich Range, Dry River, and Presidential Range) are incredible examples of what makes our nation unlike any other. From the 1964 act that created it: A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain .... retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and generally appears to have been affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable … has outstanding opportunities for solitude or a primitive and unconfined type of recreation; … as to make practicable its preservation and use in an unimpaired condition; and may also contain ecological, geological, or other features of scientific, educational, scenic, or historical value. -The Wilderness Act 1964 In addition to the ecological, scientific, historical, aesthetic, and moral reasons to protect this land, the White Mountains attract over 6 million visitors a year, many of whom specifically seek out these Wilderness areas, and their tourism dollars in the surrounding towns are what keep the local economies running. Its been over a hundred years since President Roosevelt' stewardship helped to create the Weeks act, stopping the devastating logging in the Whites that stripped the mountains into a muddy apocalyptic landscape. What we have now is a treasure, and the Trump administration can help to preserve that landscape and be aligned with the President most closely associated with protecting the greatness of the American Landscape.

"On August 25, 1916, President Woodrow Wilson signed the act creating the National Park Service, a new federal bureau in the Department of the Interior responsible for protecting the 35 national parks and monuments then managed by the department and those yet to be established. This "Organic Act" states that "the Service thus established shall promote and regulate the use of the Federal areas known as national parks, monuments and reservations…by such means and measures as conform to the fundamental purpose of the said parks, monuments and reservations, which purpose is to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations." "Rescinding this rule will remove prohibitions on road construction, reconstruction, and timber harvest on nearly 59 million acres of the National Forest System" Both of these quotes were taken directly from NPS website. National Forests were never intended for profit. They were intended to preserve and maintain. Dressing this up as "fire prevention" does not hide the intent to turn national monuments into a lumberyard. National Parks came from a time of great hardship in American History we are in a similar time now, political parties and citizens tearing each other apart. This administration has shown a dedication to preserving American History in the bold attempt to Make America Great Again, you have protected controversial Southern monuments and now must work to preserve our national forests. There is no need to worry about forest fires if you plan to let corperate greed bulldoze the only American ecosystem that is still thriving.

The Honorable Brooke Rollins Secretary of Agriculture U.S. Department of Agriculture 1400 Independence Ave. Washington, D.C. Dear Secretary Rollins, I am writing to ask you to change your mind about removing travel and mineral development restrictions on the Inventoried Roadless Areas managed by the U.S. Forest Service. We have about a million acres of National Grasslands in North Dakota, and three-fourths of that is already available for development. The remaining acres, about a quarter of those managed by the Forest Service, are off limits to development. I’m asking you to keep them that way I am reminded of the words of respected author M. Scott Momaday in his book The Way to Rainy Mountain: “Once in his life a man ought to concentrate his mind upon the remembered earth, I believe. He ought to give himself up to a particular landscape in his experience, to look at it from as many angles as he can, to wonder about it, to dwell upon it…He ought to imagine the creatures there and all the faintest motions of the wind. He ought to recollect the glare of noon and all the colors of the dawn and dusk.” Momaday might have been talking about any place in the millions of acres protected from development by the 2001 Roadless Area Conservation Rule. They are words you should heed as you consider removing that rule. Our country sorely needs places like Momady describes. One of those places, for me, is Bullion Butte, in the Little Missouri National Grasslands of North Dakota, protected by your rule. Please, don’t abandon that rule. It has now been more than 25 years since I drove the winding, two-track dirt trail to the top of Bullion Butte, the largest, although not the highest, butte in the North Dakota Bad Lands. But I haven’t missed that drive one tiny bit. Because, since the implementation of the 2001 Roadless Area Conservation Rule, I have climbed that majestic butte with my own two legs at least a dozen times. And on those climbs I have come to realize that it is not just the view from the top after a bumpy 10 or 15 minute drive, but the two or three hour ascent itself, on foot, that makes this experience so satisfying to those of us flatlanders spoiled by hikes with little change in elevation and accustomed to long views of endless prairie. At Bullion Butte, it’s the leap over the barbed wire fence from a four-foot boulder on private land, owned by the rancher I had just spoken with to get permission to cross HIS land, onto MY land, land owned by all of us: the Bullion Butte Inventoried Roadless Area. At Bullion Butte, it’s the pauses on the way up at two cattail-fringed natural springs, often home to various waterfowl, to catch my breath and take a drink from my water bottle. And at Bullion Butte, it’s the winding ascent, on a route of my own choosing, different each time, but always culminating in a sod-clutching, nearly vertical, final 50 yard climb to lift one leg, then the other, onto the last ledge, to stand atop that magnificent butte, taking the most exhilarating deep breaths of my life while staring out over the valley of the Little Missouri State Scenic River, which makes a 180-degree, 25-mile long, detour around this storied landmark on its way to the national park named for Theodore Roosevelt, America’s most important conservationist, who surely stood in this same place nearly 150 years ago as he searched the prairie for the buffalo he had come to hunt in 1883. Roosevelt ascended that butte on horseback, which we can still do today, seeing the same Sharp-tailed Grouse, Pronghorn Antelope, Mule Deer, and Golden Eagles, and yes, an occasional Rattlesnake, as Roosevelt saw, without fear of being disturbed by motorized vehicles, thanks to that Roadless Rule, which I urge my government in Washington to forsake repealing, as proposed by the USDA’s Forest Service. Please, Agriculture Secretary Brooke Rollins, and Forest Service Chief Tom Schultz, abandon your plans to repeal the Roadless Rule and leave these valuable lands to be enjoyed by the critters who live there and the humans who come—on foot—to visit them. Respectfully, Jim Fuglie 920 Arthur Drive Bismarck, ND 58501 P.S. I have attached a photo of the view from the top of Bullion Butte. Surely we don't want to see oil wells, and roads leading to them, and trucks on those roads stirring up clouds of dust, in the middle of that photo.

Please accept the following comment on the proposed recission of the 2001 Roadless Rule: I agree that a one size policy does not fit all acreages under the current 2001 Roadless Rule however current Inventoried Roadless Aeas (IRAs) have been assessed over the years through various agency reviews (forest planning, RARE II etc) and some included in wilderness bill by Congress. Many IRAs are very remote; border existing wilderness have marginal timber/wood product value or extremely costly to effectively complete vegetation and fuels management projects. There is a need for active management of forests across many IRA’s to mitigate fire risk, ensure community safety, and maintain healthy forests (and rangelands). Given that active management can currently be undertaken and is routinely done in roadless areas under exceptions to the prohibitions of the rule, again one size does not fit all and a balanced approach may be the best approach in this case. I would urge the agency to review and analyze an alternative to the proposal that 1. only rescinds IRA prohibitions that are wholly or partially within the wildland urban interface (HFRA WUI or part of county wildfire protection plan delineation). 2. Maintain current IRA designation outside of the WUI delineation to provide larger generally unroaded blocks but allowing for additional exceptions to current prohibitions for these remaining IRAs. Exemptions should be expanded to allow use of temporary (constructed and reclaimed) roads, use of existing non-classified roads as a temporary road (to be stabilized and restored to pre-project condition) to facilitate active management treatments and to define the size class of tree cutting from generally small diameter to silvicultural appropriate size classes based on habitat and site conditions. All exemptions shall be consistent with current land management plans. Thank you for the opportunity to comment on and consideration of the above comments including a viable alternative for analysis to the proposed action. Regards

As an Alaskan resident who plays, works and lives in and near the Tongass, I’m writing to oppose rescinding the Roadless Rule. The devastating result is that these ecosystems are then labeled as “unproductive. ” Luckily an organization called SeaBank released a 2024 report that put an economic value to these ecosystems to demonstrate how “productive” they really are. In this report, SeaBank found that healthy ecosystems in Southeast Alaska support more than 10,000 jobs and yields as much as $800 million per year in economic outputs to local communities; adds 6,500 jobs in the visitor services industry that leads to a combined $1 billion per year; and that the region is home to over 280,000 acres of coastal wetlands and 2,300 acres of protected coral reef areas with respective annual values of $78,500 per acre and $142,000 per acre – a combined input each year of over $24 billion. This is only the tip of the iceberg of the report, which goes on to show the economic values of the natural capital of the Tongass National Forest far outweigh any potential economic projections from further development and logging. The sustainable industries (fishing, tourism and carbon storage) already active in Tongass bring in billions of dollars annually – far more than timber can. Again, it’s important to remember commercial-scale timber harvesting in this neck of the woods is extremely cost ineffective. Living forests are economic engines. Additionally, tourism is Juneau’s second economic driver—people come here to see the glacier, the forest, the wildlife and pristine wilderness. None of these things could exist in the same way they do today if the Roadless Rule were rescinded.

Thank you for the opportunity to provide comment and support to rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule) (66 FR 3244, 36 CFR Subpart B (2001)). Constantine is a proudly Alaskan subsidiary of American Pacific Mining and operator of the Palmer Project and its copper-zinc-silver-gold-barite volcanogenic massive sulfide (VMS) project near Haines in Southeast Alaska. Constantine is committed to conducting exploration in a responsible and sustainable manner with a mission to build a project that our team, our partners, and people in the region can be proud of. The mineralization at Palmer is located within a well-known mineral-rich belt hosting over 124 documented volcanogenic massive sulfide (VMS) prospects and extending through the Tongass from southern Prince of Wales Island into central Alaska. The Greens Creek and Kensington Mines are both currently operating in this prolific mineral belt, as well as several past producing operations as well as the hundreds of mineral occurrences in various stages of exploration. The region has a rich history of exploration and mining which is supported by current operations and has potential for a robust future of responsible mineral development. The proximity of these resources to tidewater throughout Southeast Alaska are perfect conditions for new access road construction, which are primarily in remote locations and only required for relatively short distances (compared to traditional long-haul mining roads) to access loading facilities at the shoreline. Unleashing Alaska's extraordinary resource potential, as directed under Presidents Trump’s Executive Order 14153, requires access to these resources and highlights why the Tongass National Forest needs to be excluded from the 2001 Roadless Rule. A “one-size-fits-all” approach to roadless area management under the 2001 Roadless Rule is not appropriate and local land management planning processes should be employed to administer inventoried roadless areas. The 2001 Roadless Rule is a barrier to accessing mining claims and a barrier to investing in mining opportunities in Southeast Alaska. While the Mining Act of 1872 grants access to mining claims, “reasonable access” under the 2001 Roadless Rule is subjectively determined by the Forest Supervisor; simply, there are no absolute criteria by which the Forest Supervisor determines when a road is needed to support mining exploration and development and it is generally decided that activities can be “reasonably” supported by helicopters, which comes with significant issues as is it limits the number of exploration projects who can raise investment to support the expense, it limits exploration seasons to May – September; and it limits the type of equipment that can be used, typically lighter core drilling rigs. This not only adds expense to exploration companies, who do not generate operating revenues, but hampers companies like Constantine to offer fulltime employment opportunities and year-long contracts to Alaskan businesses and limits the confidence in the resource being explored. This approach downgrades investor sentiment and has deterred the kind of external investment Alaska should be fully leveraging, especially considering the increasing demand for domestic supply of critical minerals. Rescinding the 2001 Roadless Rule would provide discretion for local land managers to tailor management, as appropriate, to local land conditions. Having the greatest potential effect on robustness of the domestic mineral supply chain involves having infrastructure to support that potential and rescinding the 2001 Roadless Rule would remove several current challenges. Sincerely, Constantine

I am a Montana cattle rancher who shares 4 miles of common boundary with the USFS. I do not support the complete recission of the 2001 rule. Rather, I favor a hybrid approach that implements the decentralization intentions of the new rule, retains roadless status for the public, but allows mechanized access for USFS personal performing common sense forest maintenance and cleanup of disasters such as massive areas of beetle kill and the 5000 large Douglas Fir trees, uprooted and piled up like “pick-up sticks” on USFS ground adjoining our ranch, by a 2019 microburst that did the same to 2000 trees on our ground. I also favor mechanized access for USFS livestock permitees to perform maintenance on improvements, such as stock tanks and fences, required on their permits by the USFS. Before the IRA, public-owned ATVs swarmed the USFS areas above us, mostly driving off road, rutting and eroding the ground. They also largely ignored USFS rules and built campfires wherever they wished, regardless of the fire-danger level. And, on a private note, trespassing on our land--particularly during hunting season--was rampant and destructive. And last, we experienced nearly a steady stream of people looking for easy driving access through our yard. After the IRA came onboard, the trespassing and traffic improved somewhat, but the public, particularly hunters, continued to drive wherever they desired (not on the single designated USFS access road), camping and building fires wherever they wished, including an ATV driver my hunters observed, who drove offroad (on the Forest), stopped to bugle 2 times with his engine running, and then tossed a lit cigarette into a 40-foot diameter, 12-inch deep pile of pine needles, and drove away. My hunters emptied their canteens on it, and thought it was out. But the next morning, it was smoldering, and they told me about it, and I spent the day with a friend helping me haul water from the ranch on an ATV over a mile to the spot. There are two reasons why the IRA failed here--lack of enforcement and a rule that prevents the USFS from taking common sense actions to ensure the safety (mostly from fire) of the forest and adjoining private property. Under the IRA, enforcement has almost always been mostly non-existent, primarily because there were usually only 1 or 2 enforcers responsible for covering 2 large mountain ranges and 1 small range (ours). The enforcers were massively overworked and suffered a poor quality of life due to their inadequate numbers. So, retention became an issue which lingers today. WRT USFS mechanized access for common sense tasks like eliminating the massive fire hazard created by the 2019 microburst, we hired loggers for what they could earn from the marketable timber they salvaged. I offered the then-Ranger the opportunity to join us, because we have so much contiguous property, but the USFS would not participate and, in my opinion, hid behind the rule and refused to seek an exception after I read the rule and showed them the pathway to apply for an exception that would allow them to join us in removing a huge danger to public and private land, and potentially life. So, the IRA failed here because there was no enforcement and the USFS would not seek an exception to eliminate a dangerous fire hazard that remains today. Last, carrying fencing supplies and tools on horseback is beyond ridiculous and complicates an already time-demanding task. Summary: So, for the above reasons, I support a new rule that still prohibits mechanized public access; allows mechanized USFS access to complete common-sense projects that improve the Forest and preclude forest fires, particularly where USFS adjoins private ground; and mechanized access for permittees to complete USFS-prescribed maintenance on the USFS improvements they're responsible for.

Affected Native American Species: American Black Bear Grizzly Bear Mountain Lion (Cougar) White-tailed Deer Mule Deer Elk Moose Wolves Bison Red Fox Gray Fox Beaver American Bighorn Sheep Bald Eagle Peregrine Falcon Northern Goshawk Wild Turkey Pileated Woodpecker California Condor Great Horned Owl Western Fence Lizard Gopher Snake Timber Rattlesnake Alaska Garter Snake American Bullfrog Wood Frog Spotted Salamander Monarch Butterfly Western Honeybee Cedar Beetle Douglas Fir Western Red Cedar Ponderosa Pine Lodgepole Pine White Pine Sitka Spruce Aspen Redwood Balsam Fir Black Spruce Mountain Laurel Blueberry Rhododendron Chokecherry Serviceberry Snowberry Indian Paintbrush Columbine Wild Ginger Black-eyed Susan Trillium Lady’s Slipper Orchid Bracken Fern Maidenhair Fern Tree Moss Reindeer Lichen Wintergreen Creeping Jenny Wild Strawberry To be replaced by: Concrete Steel Glass Reinforced Concrete Brick Cement Aluminum Asphalt Stone Plastic Fiberglass Insulation Plaster Ceramic Tiles Vinyl Asphalt Concrete Gravel Bitumen Crushed Stone Reinforced Steel Mesh Geotextile Fabrics Plastic This world holds beauty that should not be tainted, but appreciated. We learn lots of good values from nature that our children could benefit from. Let’s protect it. There must be other solutions or workaround to the measure being considered.

Dear USDA and Forest Service decision-makers, I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. This national policy has protected roughly 45 million acres of inventoried roadless areas across the National Forest System for more than two decades. The truncated public comment period—just 21 calendar days (or 14 business days)—is a deeply inadequate timeframe for meaningful public participation, especially given the Rule’s history: originally developed through hundreds of public meetings and over 1.6 million public comments, 95% of which supported strong protections. This abridged timeline undermines the will of the people, and smacks of a deliberate effort to minimize scrutiny and expedite rollback. Critics, including former Roadless Rule architect Mike Dombeck, have flagged this truncated timeline as an “unusual choice” and warned that it fails to foster the kind of public trust and collaboration that legitimized the original rule. The Roadless Rule has long served as a crucial safeguard for clean water, habitat connectivity, climate resilience, and backcountry recreation, supporting rural economies and tribal communities alike. Allowing local decision-making to override these national protections risks fragmentation of safeguards and erosion of ecosystem integrity. While supporters suggest that rescission is necessary for wildfire management or timber access, existing exceptions already permit fuel reduction projects near communities, without jeopardizing intact landscapes. A broader reversal would disproportionately damage water sources, wildlife corridors, and recreational economies without delivering meaningful forest health or hazard reduction benefits. I urge the Forest Service to extended the public comment window to at least 60–90 days, schedule regional public hearings, and ensure the upcoming draft Environmental Impact Statement includes a full analysis of alternatives such as: *Maintaining the Roadless baseline while allowing time-limited, decommission-on-completion access for hazard control *Evaluating long-term costs of new roads and their maintenance liabilities *Assessing impacts to drinking water, fisheries, and outdoor recreation economies *Consider cumulative fragmentation effects on habitat and invasive species These steps are essential to ensure a transparent, comprehensive, and scientifically robust process. Given the magnitude of this proposed rollback—the largest in conservation history—we deserve a process grounded in public input, rigorous analysis, and respect for democratic participation. Thank you for considering these comments. Sincerely, Concerned Citizen South Carolina

I do not trust this administration's motivations in any way that they are interested in stewardship of these national resources or care of the ecosystems they represent. It was made very clear in Project 2025 that the goal of this deregulation is to enrich the already wealthy, permit pollution and destructive resource management unfettered, and make lands less accessible for outdoor recreation, hunting and fishing by the public in favor of enabling private industry to make money without an eye towards the future of these irreplaceable treasures. If plans need to be made to manage old growth and reduce forest fires, those plans can and should be made public where people knowledgeable in the field can weigh in on actual, concrete initiatives rather than "streamlining" protections into "whatever the highest bidder says is OK." I cannot help but think about all of the alleged "waste" found by DOGE that has since resulted in chaos, in many blameless professionals being fired and then having to attempt to be hired back, and management of THE PEOPLE'S resources being compromised as a result. THE PEOPLE. Not a hundred billionaires whom the administration seems to think are the only people who count. Not just tree-hugging "liberals" but outdoorsmen and women of all kinds.

The U. S. Department of Agriculture has proposed repealing the 2001 Roadless Rule, which established prohibitions on road construction, road reconstruction, and most timber harvesting in inventoried roadless areas across roughly 58 – 59 million acres when adopted and, due to subsequent state-specific rules in Idaho and Colorado, applies today to nearly 45 million acres of National Forest System lands (U.S. Forest Service, 2025, Congressional Research Service, Aug. 28, 2020). The proposal provides a three-week public comment period, a shorter window than the extensive outreach for the original rulemaking, which included hundreds of public meetings and more than 1.6 million public comments (Houston Chronicle, Aug. 27, 2025, Federal Register, Jan. 12, 2001). The stated justification centers on increasing access for timber. Forest Service planning documents indicate that within inventoried roadless areas, about 9 million acres are considered suitable for timber production (a subset of the ~58.5 million acres designated), and that economically feasible harvest is generally limited to areas near existing roads. Under alternatives that restrict new road construction, projected timber offer volumes within roadless areas were estimated to decline by 73 – 85% relative to No-Action baselines (USDA Forest Service Specialist Report, Nov. 2000). In parallel, a Department-wide reorganization would phase out the Forest Service’s nine Regional Offices, consolidate research stations, and relocate staff with the stated aims of reducing bureaucracy and centralizing support functions. Observers have raised concerns that such changes could concentrate expertise and affect regional capacity for wildfire management, pest response, and environmental review (Montana Free Press, July 28, 2025, The Guardian, July 24, 2025). Summary: These initiatives represent a shift in the balance of federal forest governance. Proponents view them as opportunities to streamline management and expand resource access, while critics highlight risks to conservation continuity and the Forest Service’s long-term technical capacity. The trade-offs underscore the central policy question: how to reconcile short-term efficiency and resource development with the enduring mandate to protect public lands.

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