Roadless Rule public comment guide: What’s happening, why it matters, and how to make your comment count before Sept. 19th

Madeleine
18 hours ago
9 min read

Updated: 14 hours ago

The Roadless Rule is one of the most important conservation policies in the United States, protecting more than 58 million acres of national forests from road-building and large-scale logging. But right now, the U.S. Department of Agriculture (USDA) is moving to repeal it. They’ve launched a fast-moving federal process that includes a public comment period ending September 19, 2025. Now is our time to act.

Public comment periods can feel mysterious (or, honestly, futile), but they are a critical part of federal rulemaking, and they really do matter (I promise). So, I want to pull back the curtain a bit and give some insight into this process so you can understand how to make the most impact here.

At the end of the day, I want you to feel empowered. Agencies are legally required to read, consider, and respond to substantive comments. History shows that strong, evidence-backed comments have changed outcomes before, so this means your voice truly matters.

What’s in this article ⬇️

What the Roadless Rule is (and why it matters)
How the repeal process works, including what the USDA is doing differently this time with its Notice of Intent and Environmental Impact Statement (EIS) and a timeline of events.
Where we are now, and why the current 21-day public comment period is so urgent.
How public comment periods work. Specifically, what agencies look for, why they matter, and real-world examples of when they changed outcomes.
How to write a strong public comment, including tips, strategies, and common mistakes to avoid.
Talking points for Roadless Rule comments. Sharing specific issues you can raise now, from ecological impacts to Indigenous rights to wildfire risks.

TL;DR

The Roadless Rule is a federal regulation (different from a law) protecting ~58 million acres of national forests in the United States from new roads, large-scale logging, and exploitation.
The USDA is attempting to repeal it through the federal rulemaking process, which requires a public comment period.
Public comments actually matter, so we need to take this seriously. Agencies must review feedback, take it into consideration, and publish it.
History shows strong comments have influenced outcomes in the past. Your voice MATTERS!
A strong comment is personal, specific, evidence-based, and constructive. It’s not just a numbers game here, everyone needs to be thoughtful and strategic with their comments.
The current repeal proposal has only a 21-day comment window, making it urgent for the public to weigh in.
Public comment period for the Roadless Rule ends Sept. 19th, 2025
Submit your comment here!

About the Roadless Rule

The Roadless Rule, created back in 2001, is a federal regulation that protects about 58+ million acres of national forests by limiting new road construction and large-scale logging, helping preserve wildlife habitat, clean water, and recreation opportunities. The Department of Agriculture (USDA) is attempting to repeal this rule, removing vital protections and opening 30% of our national forests up to irreparable damage.

One important distinction here is that the Roadless Rule is not a law passed by Congress. Instead, it’s a federal regulation created by the U.S. Forest Service under the authority of the USDA. Because it’s a regulation, it carries the force of law but can be changed or repealed by the agency that created it, without requiring an act of Congress.

That flexibility is both its strength and its weakness.

How does the repeal process work?

Repealing the Roadless Rule must follow the Administrative Procedure Act (APA) and other federal laws, like the National Environmental Policy Act (NEPA).

Usually, an agency will:

Publish a Notice of Proposed Rulemaking (NPRM) in the Federal Register and open a public comment period (required under the APA).
Draft a rule: After reviewing comments, the agency may revise its proposal. A second round of public comments often follows.
Finalize the rule: A final rule is published, along with the agency’s responses to substantive comments.

The process for the Roadless Rule

The USDA is handling this process slightly differently for the Roadless Rule than what we usually see.

On August 29, 2025, the USDA didn’t publish a proposed rule. Instead, it issued a Notice of Intent (NOI) to prepare an Environmental Impact Statement (EIS), as required by NEPA. This notice also opens the current 21-day public comment period.

At this stage, the goal is to raise issues that should be addressed in the Draft EIS. Things like ecological impacts, wildfire risks, Indigenous land use, or recreational consequences.

According to the notice, the USDA plans to publish the proposed rule together with the Draft EIS in March 2026, which will trigger another (and much larger) public comment period.

This second comment period will be the big opportunity for scientists, forestry experts, legal scholars, and advocates to weigh in with technical critiques. If the agency relies on flawed data, weak methodology, or ignores relevant evidence, commenters can flag those gaps, and the USDA will be legally required to respond to every substantial issue raised.

Finally, the USDA is aiming to issue the Final Rule and Final EIS by late 2026.

At that point, the rule could be fully repealed, upheld, or modified. But even then, it could face legal challenges if the process is found to have ignored substantive public input.

Roadless Rule timeline at a glance

August 29, 2025: USDA issues a Notice of Intent (NOI) to prepare an Environmental Impact Statement (EIS), not a proposed rule. This triggers a 21-day public comment period.
WHERE WE ARE NOW ➡️ August 29 – September 19, 2025: Current public comment period. Citizens can submit feedback through a public comment portal on the official government website or via mail. This is the public’s chance to highlight what should be analyzed before the draft is even written (ecological impacts, wildfire risks, Indigenous land use, recreation, etc.).
March 2026: USDA plans to release the Proposed Rule + Draft EIS. This will open another, longer public comment period for detailed, technical feedback.
Mid–Late 2026: USDA reviews comments, responds to substantial feedback, and finalizes its analysis.
Late 2026: USDA aims to issue the Final Rule and Final EIS, which could repeal, uphold, or modify the Roadless Rule. The outcome could also face legal challenges if the process is found lacking.

What this means for us, the general public

Our voices matter right now! The 21-day public comment period runs until September 19. This is an extremely short window that barely allows room for meaningful public participation on such a consequential policy, so we need to act quickly. While we will have another opportunity to leave comments in 2026, it’s important we don’t miss this period of time now because we will get to shape the draft before it even gets written. Leave your comment today.

All about public comment periods

Public comment periods can feel kind of ambiguous because it feels like you’re just screaming into the void. You write a comment, hit submit, and then hope and pray your comment is heard. So, let’s draw back the curtain a bit and explain what actually happens.

What exactly is a public comment period?

A public comment period is a legally required opportunity for the public to weigh in on proposed federal rules. Agencies must accept, read, and respond to substantive feedback, and comments become part of the official record.

What constitutes as “substantive feedback?”

You don’t have to be an expert or a lawyer to participate. Anyone can submit their views via writing (through he online portal, by mail, or at in-person hearings in some circumstances).

This isn’t just a numbers game. It’s actually really important that people submit thoughtful comments, not just “you suck.” 😂 While agencies do take note of overwhelming public opposition or support, what matters most are substantive comments.

Personal stories: Unique experiences showing how you use or benefit from roadless forests.
Evidence and data: Scientific research, economic impacts, or environmental facts that support your position.
Specificity: Citing the section of the proposed rule you’re addressing, or pointing out overlooked consequences.
Constructive suggestions: Proposing alternatives or modifications rather than blanket opposition.

Agencies are legally obligated to respond to major issues raised in substantive comments. This response shows up in the final rule’s preamble or in a “response to comments” section.

Do public comments really make a difference?

YES! While they don’t always stop bad policy, strong comments influence agency decisions and create a public record that’s invaluable for litigation or future advocacy.

Examples:

Roadless Rule itself (2001): More than 1.6 million comments (the most in history at the time) helped cement its adoption.
Alaska’s Tongass National Forest (2021–2023): Over 112,000 comments in support of restoring Roadless protections helped persuade the USDA to reinstate the rule.
Bureau of Land Management Public Lands Rule (2023): Widespread public support, from individuals to businesses to local governments, strengthened the case for its adoption.

Comments matter. Agencies cannot simply ignore the public record without risking legal defeat and public scrutiny. It’s so rare we actually have opportunities to have our voices heard in legal processes like this, it’s important we take this seriously.

How to write a strong public comment

Writing an effective comment isn’t about length; it’s about substance. Here’s how to make your voice count.

Introduce yourself: Explain who you are and why you care. Personal connections add credibility.
Be specific: Reference the section of the rule or particular impacts you’re addressing. For example, I specifically talked about how repealing the Roadless Rule will not help increase accessibility for disabled people in my comment.
Use evidence and facts: Cite scientific studies, economic data, or environmental facts. You can also include links and upload files.
Tell YOUR story: Agencies value hearing about how rules affect real people. Share your lived experience. You can even submit photos of yourself with your comment.
Propose alternatives: If you oppose repeal, suggest what should be done instead.
Stay respectful: While it’s tempting to leave a rambling, angry comment when situations feel so dire and high-stakes, it’s important you keep a level head in your comment. Clear, organized points carry more weight than emotional venting
Don’t overthink it: Comments don’t need legal jargon. You don’t need to run it through ChatGPT to make it sound “more professional” or unlike yourself. Yes, you need to be clear and organized. But you also don’t need to be the best writer in the world.

Talking points for Roadless Rule public comments

Since this comment period is tied to the Notice of Intent to prepare an Environmental Impact Statement (EIS), the most powerful comments will highlight what issues the USDA must study in depth for the draft EIS. Here are some talking points people can use to shape their public comments.

⚠️Please NEVER copy and paste anything for public comments. It’s critical you submit a unique and original comment.

Ecological impacts

Emphasize how roadless areas protect biodiversity, wildlife corridors, and watersheds.
Raise concerns about habitat fragmentation from roadbuilding and its effects on threatened species (e.g., grizzly bears, salmon, spotted owls).
Suggest that the EIS must evaluate long-term ecosystem health and climate resilience, not just short-term logging outputs.

Wildfire risks

Stress that science shows roads can actually increase wildfire ignition risks (from human activity and equipment) and complicate suppression efforts.
Wildfires start 4x more often near roads, with 90% of fires igniting within half a mile of a road.
Urge the USDA to analyze whether expanding road networks undermines forest resilience and adaptive management strategies.
Request that the Draft EIS include a comparative study of wildfire outcomes in roadless vs. roaded areas.

Indigenous land use & cultural resources

Call for meaningful Tribal consultation and inclusion of Indigenous ecological knowledge.
Ask the USDA to examine impacts on treaty rights, sacred sites, and traditional uses of forestlands.
Suggest that the Draft EIS include case studies of Indigenous stewardship practices in roadless areas.

Recreational & community consequences

Share personal stories of hiking, hunting, fishing, foraging, or spiritual experiences in roadless areas.
Highlight how these forests provide non-extractive economic benefits like recreation tourism, clean drinking water, and carbon sequestration.
Recommend that the Draft EIS analyze both economic losses from potential logging and gains from outdoor recreation and ecosystem services.

Climate change implications

Point out that roadless forests are major carbon sinks, critical to U.S. climate commitments.
Urge the agency to study how repealing protections could accelerate greenhouse gas emissions and undermine climate resilience.

Alternatives & constructive suggestions

Ask the USDA to fully evaluate the “no-action alternative” (keeping the Roadless Rule in place).
Recommend that instead of blanket repeal, they explore targeted management solutions that allow localized fuel reduction while maintaining core protections.
Propose expanding investment in accessible trails and adaptive facilities (rather than roads) to improve recreation access, specifically for disabled people.

Specificity matters

When possible, cite particular places (e.g., Maple Pass Loop, Tongass National Forest, etc.) and describe what would be at risk if roads and logging expanded.
Flag any gaps in the Notice of Intent where ecological, social, or economic consequences are not mentioned, and request they be included in the Draft EIS.

At this stage, it’s less about debating the final outcome and more about ensuring the Draft EIS fully studies all the ecological, cultural, social, and economic dimensions of repealing the Roadless Rule. The stronger and more detailed the issues raised now, the harder it will be for USDA to cut corners later.

We need to act now

The Roadless Rule is one of the most important conservation safeguards in America, and right now it’s on the chopping block. While the USDA can propose to repeal it, the law requires public input before any decision is finalized. That means every comment submitted becomes part of the official record, influencing not just today’s decision but how courts and future administrations view this issue.

History has shown that when the public turns out in force, agencies pay attention and sometimes even reverse course. That’s why it’s essential to submit a comment and encourage others to do the same.

Since the Roadless Rule isn’t a statute (it’s a regulation), it makes it vulnerable. But also means the public has a direct line of influence through the public comment process. I promise, your comments don’t just vanish into a void. They are legally required to be considered, and they’ve shaped major conservation decisions in the past.

If you care about keeping America’s wild forests roadless, your comment matters. It’s your chance to speak directly into the policymaking process, and history shows it works. Let’s go!