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I writing to urge you to choose Alternative 1: Status Quo/No Action in your final ruling on the proposed Roadless Rule Rescission. There are many compelling reasons to oppose the rescission. I’ll list just a few of them, focusing on ones that are particularly pertinent in Montana, which is where I live. I’m sure that you’re hearing about most of these from other folks, so I don’t think there’s a great deal of need for me to go on and on. The public is opposed—overwhelmingly so—to removing protections for roadless areas. More than 99% of responses received thus far are against the rescission of the Roadless Rule. Even amongst folks who can’t be bothered with writing letters, support for Roadless Areas has been around 76%. These are public lands we’re talking about, and how the public would like to see them used ought to weigh heavily in the decision-making process. Municipal Watersheds will be degraded. Building more roads in our National Forests will increase erosion, which will add to run-off and water purification costs. More than a third of Montanan’s water comes directly from or is downstream of roadless areas. Wildlife habitat will be further fragmented. I’m lucky enough to make my home in the Greater Yellowstone Ecosystem (outside Livingston, MT), which is “the most intact temperate ecosystem in the world,” according to wildlife biologist Doug Smith. Removing the roadless buffer along the edges of this ecosystem will harm wildlife habitat if/when extractive industries move in. The Greater Yellowstone area draws visitors from around the world and has been studied and written about by many. We need more protections—not fewer—for an ecosystem as important as this one. Recreation Economy. Tourism is a big deal Montana, supporting 1 in 11 jobs. Outdoor recreation is also important to Montana residents, making up 4.9 percent of Montana’s GDP. 5.9 of Montanans work in fields related to outdoors recreation. Much of this recreation takes place on public lands that are easily accessible from cities and towns, and these places often include IRAs. It seems unlikely that the extractive industries enabled by rescinding roadless protections will provide a net gain for Montana’s economy, since tourism and outdoor recreation would likely suffer. Maintenance Backlog for Existing Forests Service Roads. If we can’t take care of the ones we already have, we probably don’t need more. Enough said. Private Inholding Access. This is a big one, especially for those of us who live near or like to recreate in the Crazy Mountains. The Crazy Mountains are made up of “checkerboard” public and private land ownership, though some sections (not the right ones, in my opinion) were consolidated a couple of years ago. Most of the checkerboard is currently within the Crazy Mountain IRA. If roadless protections are removed, it will be easier for owners of private inholdings to petition for permission to build a road to their property. These roads would fragment wildlife habit, disrupt public recreation, and have a negative impact on tribal resources. The boon this would provide for owners of formerly difficult-to-access private inholdings is substantial, and casts new light on the checkerboard consolidation deal brokered by the Yellowstone Club in 2025. Wildfire Reduction. This is one of the primary reasons given by the Forest Service for its need to rescind the Roadless Rule. However, scientific evidence does not support the building of roads as a way of reducing wildfire risk—in fact, human caused ignitions in Montana are more than 8 times higher within 100 yards of a road than they are on more remote forest service land. I live a couple of miles from an IRA that runs along the northern edge of Absarokas, and the wildfires we’d had in this area since I’ve lived here tended to be fought by air. Some ignitions occurred on private property (often, a vehicle was involved), others were caused by lightning strikes, but the outcome was the same: the sky was abuzz. At times, firefighters were dropped into wilderness areas to fight fire on the ground—but roads provided little in the way of meaningful firefighting access. Plus, there’s enough wiggle room in the current Roadless Rule to allow for forest thinning and controlled burns in the WUI. Though it will never be perfect, I believe that the Roadless Rule and wildfire protection for our towns and neighborhoods in the urban interface can successfully coexist. Thanks for hearing me out. There’s plenty more I could say, but I believe I’ve gone on for long enough. I hope you make a decision that serves the general public, not a select few. Please go with Alternative 1. The other options serve neither our forests nor the people who love them.

I oppose rescinding the 2001 Roadless Area Conservation Rule. My position is based on more than twenty years of experience in the Crazy Mountains and six years of documented engagement with Forest Service processes, including formal comments, objections, and correspondence submitted between 2018 and 2024. These materials show a consistent pattern of procedural defects in local and project‑level decision‑making—failures that demonstrate why national‑level roadless protections remain essential. In 2018, I documented that the Forest Service failed to conduct required feasibility analyses, notify tribal governments, or complete NEPA review for the Porcupine Lowline Trail #267 proposal. Landowners had obstructed public access for sixteen years, and the proposed reroute rewarded that obstruction. Sensitive wildlife habitat was not analyzed, and nearly year‑long meetings between the Forest Service and the Crazy Mountain Working Group were not open to the public. These failures showed early and clearly that local processes were vulnerable to non‑transparent decision‑making and inconsistent enforcement of public access rights. In 2019, I documented that the Forest Service failed to conduct required public scoping for the South Crazy Mountains Land Exchange and published legal notices only in non‑tribal newspapers, despite the Crazy Mountains being an area of cultural importance to the Crow Tribe. The preliminary environmental assessment was premature, and the absence of scoping prevented meaningful public participation. These failures demonstrated a pattern of excluding tribal communities and bypassing required NEPA steps. In 2022, I documented that combining scoping with the Preliminary Environmental Assessment for the East Crazy Inspiration Divide (ECID) proposal eliminated meaningful public input and advanced the interests of non‑Federal parties. I also documented that measurable agency action on access issues occurred only after litigation was filed, showing that enforcement of public rights depended on external pressure rather than consistent agency practice. In 2023, I documented that non‑agency groups “masquerading as Federal Advisory Committees” misled the public and convoluted the NEPA process, and that the Forest Service later clarified these groups did not advise the agency, contradicting years of public messaging. I also documented that the Sweet Grass County Commission received the ECID proposal before the Forest Service, that the Crazy Mountain Access Project solicited and analyzed public comment without legal authority, and that a key specialist report (Forestoration Narrative) was withheld until after comment periods closed. These defects demonstrated systemic weaknesses in transparency, record completeness, and public participation. In 2024, I documented that Forest Service communication to Congress omitted substantial public and conservation‑group objection and mischaracterized landowner interests. This showed that procedural irregularities and incomplete disclosures extend beyond NEPA documents and into communications with Congressional oversight bodies. Taken together, these documented failures—spanning NEPA, NHPA, transparency, record completeness, tribal consultation, and public participation—demonstrate that local and project‑level processes are not sufficient to protect roadless values. Removing national‑level safeguards would expose intact watersheds, wildlife habitat, and culturally significant landscapes to decision‑making processes that have already shown systemic weaknesses. The Roadless Rule provides consistent, durable protections that prevent the types of procedural failures documented in the Crazy Mountains from determining the fate of roadless landscapes. For these reasons, I respectfully request that the Forest Service retain the 2001 Roadless Area Conservation Rule. Thank you for considering my comment. Sheila Royston Wilsall, MT

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Lindsey Hanna and I am a software engineer in Livingston, Montana. In an ever-increasing digital world, protecting our public lands is of the utmost importance. I rely on public access areas for trail running, hiking, skiing, camping, backpacking, viewing wildlife, hunting, fishing, and just generally appreciating the abundance of amazing opportunities the great outdoors has to offer. I regularly recreate in the Bridger Range, the Crazy Mountains, the Gallatin Range, and the Absorakas, all of which are currently partially or fully protected under the roadless rule. These areas are my access to all the outdoor activities I enjoy, and rescinding the Roadless Rule threatens this access. The Roadless Rule already allows for fire mitigation and management tactics and it's well established fires are 4x more likely to ignite on or near roads. Increasing the road system will only serve to increase the number of fires. Additionally, rescinding does not make fiscal sense. The Forest Service and other public entities already cannot maintain the road system currently in place, and already has an enormous deferred backlog. We have neither the funds nor the personnel to expand and adding new roads will exacerbate these problems. For over two decades the Roadless Rule has conserved some of the best of America's native wildlife habitat, clean water, and phenomenal backcountry recreation, fishing, and hunting opportunities, and it is all of our responsibility to keep doing that for ourselves, our country, and all generations beyond. I 100% support the No Action Alternative to keep the Roadless Rule as it currently stands in place. We need the Roadless Rule, and we need you to keep it in place.

Park County Environmental Council (PCEC) submits these comments on behalf of our 500 active members and 2,600 regional supporters who live, work, and recreate in Park County, Montana. Since 1990, our mission has focused on protecting the wildlife, critical habitat, public lands, water resources, and community resilience that define the Upper Yellowstone and Shields River watersheds and the communities within them. PCEC members directly rely on and use specific Inventoried Roadless Areas (IRAs) across the Custer Gallatin National Forest. Our members regularly hike, hunt, and forage in the Crazy Mountains IRAs, depend on municipal and agricultural headwaters originating in the Absaroka Range IRAs and access backcountry recreation and outfit in the Hyalite-Porcupine-Buffalo Horn Wilderness Study Area and Gallatin Range IRAs. Any degradation of these specific roadless units directly impairs the indigenous sacred character, secured aesthetic, recreational, economic, and procedural interests of PCEC and its individual members. Park County Environmental Council stands in firm opposition to the U.S. Department of Agriculture (USDA) and U.S. Forest Service’s (USFS) proposed rule change to rescind the 2001 Roadless Area Conservation Rule and strongly advocates for the decision of Alt. 1 – No Action. PCEC specifically requests that the USDA and USFS address the following core legal, procedural, and environmental objections: Objection 1: Failure to analyze reliance interests under the APA by arbitrarily revoking two decades of established landscape protections without considering how local communities and wildlife depend on them, directly threatening Park County’s local culture, traditional ways of life, quality of life, and natural amenity economy. Objection 2: Compromising federal trust obligations, sacred site integrity, and treaty-reserved tribal resources. Objection 3: Degrading high-value natural assets driving the local amenity economy while imposing severe, unanalyzed road maintenance fiscal liabilities on taxpayers. Objection 4: Relying on an incorrect argument that rescission mitigates wildfire risk while failing to analyze reasonable alternatives under NEPA. Objection 5: Threatening the primary hydrological engine and clean drinking water infrastructure of the regional water supply and violating binding soil disturbance limits. Objection 6: Causing direct negative economic and operational impacts on local agricultural producers and forest permittees. Objection 7: Fragmenting irreplaceable wildlife corridors, disrupting Greater Yellowstone Ecosystem connectivity, and increasing mortality risks for species listed under ESA Section 7. Objection 8: Failure to analyze illegal NEPA segmentation, statutory cumulative environmental impacts under NEPA, and carbon emissions under Executive Order 14072. As established, the 2001 Roadless Area Conservation Rule preserves 851,000 acres of IRAs across the Custer Gallatin National Forest alone. Situated in the northern Greater Yellowstone Ecosystem (GYE), Park County serves as the primary year-round gateway to Yellowstone National Park. The 2001 Rule represents one of the most effective, successful, and scientifically supported conservation framework policies in modern public land management. By maintaining strict protections across IRAs, USFS safeguards the ecological integrity, headwater hydrology, cultural heritage, and amenity-driven economic foundations that sustain Park County, the Upper Yellowstone and Shields River watersheds, and the broader GYE. Rescinding the Roadless Rule and replacing national safeguards with localized, fragmented management regimes would initiate irreversible landscape fragmentation across the Custer Gallatin National Forest and beyond. PCEC submits these comments to preserve all factual, ecological, and legal challenges for administrative appeal and judicial review under NEPA, ESA, the Administrative Procedure Act (APA), the National Forest Management Act (NFMA), and the National Historic Preservation Act (NHPA). OBJECTION 1: We object to the removal of over two decades of successful landscape protection and conservation precedent and the failure to analyze reliance interests under the APA. We object because these changes directly threaten Park County’s local culture, traditional ways of life, quality of life, and natural amenity economy. This decision fails to look at how our local communities and wildlife are intertwined with and rely on these protections across the Custer Gallatin National Forest. USFS needs to directly address why its prior factual findings regarding the environmental, ecological, and watershed benefits of roadless protections are no longer valid. A full letter with explanations and references for each objection is attached. Missings files can not be uploaded due to the file limit on this platform. Please contact for any reference requests.

I firmly believe that Alternative 1 (no rescission of the Roadless Rule) is the best option for the American public as it preserves roadless areas, maintains wildlife habitat, and enhances outdoor recreation. Over the last 15 years I have worked for the Forest Service across 3 national forests as a Hydrologist (I am submitting this comment anonymously for fear of retribution). There are approximately 370,000 miles of roads across the national forest system, the vast majority of which are in a deteriorated condition, and I have observed sediment deposits in streams and wetlands from unmaintained roads. The USDA claims that increased road building is necessary to reduce wildfire activity by allowing for fuel reduction projects. This is a misguided theory, as analysis by the Forest Service itself found that 90% of wildfires start within 0.5 miles of a road, and that only 3% begin within roadless areas. More roads = more cars = more sparks, abandoned campfires, and discarded lit cigarette butts. I was evacuated for 18 days during the 2021 Caldor Fire on the Eldorado National Forest, which was caused from target shooting along a Forest Service road. I worked as a fire fighter, resource advisor, and burned area emergency response Hydrologist. There were roadless areas located within the fire perimeter, but in no way did a lack of roads impact fire fighting abilities as other roads were located nearby. I am an avid outdoor recreationist and spend countless hours hiking, backpacking, mountain biking, and skiing across Forest Service lands, the majority of which occur in roadless areas. Constructing roads in these areas would negatively impact these activities. I hiked the entire Pacific Crest Trail, and there are 63 roadless areas along 288 miles of the PCT in California, Oregon and Washington. Loss of these roadless areas would negatively impact my experience due to noise pollution, dust, and habitat fragmentation. I currently live within the Greater Yellowstone Ecosystem, which generates millions of dollars in visitors coming to the area to view wildlife and fish in blue-ribbon streams, both of which would be negatively impacted by constructing additional roads. The money generated from outdoor recreation far exceeds any potential increase in money that would be generated with logging, the vast majority of which would not go into the local economy. I just spent the last 8 days backpacking in the Crazy Mountains of Montana (north of Livingston, MT), which already has a dense road network. Constructing roads in the roadless areas of this mountain range would have negatively impacted my experience. In summary - there are already an abundance of roads across the national forest system, the vast majority of which are in terrible condition and generating excessive sediment that is negatively impacting water quality, and construction of new roads would lead to increased human-caused wildfires and degradation of outdoor recreational experiences. Please do the responsible thing for the American public and DO NOT repeal the roadless rule.

To the Department of Agriculture: I grew up in Montana, and have worked for the Forest service in multiple capacities as well as numerous years of recreating in Wild areas across the United States. For a person who has sought out roadless public land across different regions and in different seasons, I'd say the 2001 Rule is one of the clearest expressions of what the public land system is supposed to protect — and rescinding it would be a clear statement about what it isn't. I grew up exploring places like the Crazy Mountains as well as others nearby. My wife and I recently hiked to the blue lakes, where we were able to access an alpine area filled with unique wildflowers with no other person in sight. Places accessible only by foot, that are protected from destruction by bulldozers and tires Regarding the Crazy Mountain in the Gallatin National Forest, Montana: Alpine and Subalpine Climate Refugia — The area's high-elevation ecosystems—Rocky Mountain Alpine Turf, Alpine Dwarf-Shrubland, and Whitebark Pine/Subalpine Fir Woodland—occupy the summits and ridges of peaks exceeding 10,700 feet and represent climate refugia where species can persist as lower-elevation habitats warm. Whitebark pine, a federally threatened species and IUCN-listed endangered species, depends on these high-elevation zones where it grows in association with subalpine fir; the species is already declining across the West due to white pine blister rust and mountain pine beetle. Road construction at high elevations would remove the canopy structure that whitebark pine requires and would increase human access that spreads invasive pathogens, directly undermining recovery prospects for this species in one of its remaining strongholds. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. “Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2)” The Department's obligation under the APA is to provide reasoned explanation commensurate with the significance of the policy change; that obligation has not been met, and rescission should be denied. All the best, CommentID: RLC-20261006-E8VZJB

Dear Director, My name is Birgit Graf, and I am writing in response to the proposed rescission of the Roadless Area Conservation Rule (Docket No. FS-2025-0001). I have lived in Montana for decades, and feel very fortunate having had the opportunity to spend time in places like the Bob Marshall and Great Bear Wilderness, the Swan Range and the Badger-Two Medicine Area. I have enjoyed the beauty and serenity of these undisturbed, quiet places, which make Montana unique, as large intact connected landscapes are increasingly hard to find. I am very concerned about the future impacts of the proposed rescission of the Roadless Rule. Whereas Glacier Park, the Great Bear Wilderness, the Bob Marshalls enjoy protections from industrial development due to congressional designations, the integrity of places like the Badger-Two Medicine, the Swan Range or the Crazy Mountains is only protected by the Roadless Rule. Without that protection the likelihood of industrial development with accompanying negative impacts is very high. Therefore I strongly support the "No Action" alternative (Alternative !). !.The negative ecological impacts resulting from road building include wildlife habitat loss and fragmentation, loss of important migratory corridors, decrease in species diversity, soil erosion and stream pollution, harm to threatened and endangered species, increase in invasive insects and weeds, also a significant increase in noise and air pollution. 2. The economic consequences include loss of revenue due to declining tourism, as many out-of-staters visit the State esp. because of its magnificent scenery and wild beauty, as do many Montanans (like me), who enjoy hiking, boating, fishing and other recreational activities, which support local businesses like outfitters, guides, tour operators etc. 3. While the proposal for rescission does not mandate road-building and timber production and other industrial activities, according to the USDA, it is alligning with Executive Order 14225 "Immediate Expansion of American Timber Production" and EO 14154 "Unleashing American Energy" of 2025. Considering the 2025 congressional OBB Act, which mandates yearly increases of timber production on USFS administrated land as well as on Bureau of Land Management land, the quota can only be met by industrial-scale operations, and road building in the currently inventoried roadless areas seems inevitable. Besides moving the USFS Wildland Fire Operations over to the Department of the Interior, creating a new US Wildland Fire Service, and proposing more widespread budget cuts and the elimination of several offices (like the Collaborative Forest Landscape Restoration Program), the released USDA FS proposed budget for FY 2027 seeks to refocus the Forest Service on its core land and ressource management mission through timber production. This goal is reflected in the fact that the line item for forest products is more than quadrupled. The result is very limited room for multi-use. 4. A major reason for the rescission of RR is, according to the USDA, that the rule prevents efforts to improve forest health, by aiding over grown forests, and to effectively deal with increasingly severe and long lasting wildfire seasons. It has been well established that roads actually increase the likelihood of wildfires. According to the National Park Service almost 85% of wildfires are human- caused, and ignite in close proximity to roads. The challenges of community protection in the wildland-urban interface, fuel reduction, and strengthening the resilience of forest ecosystems can be and has been successfully met within the framework of the Roadless Rule. Furthermore, it is difficult for me to understand how the aim of improving the federal response to wildfires, as stated in 2025, can be achieved, considering the major budget cuts and reductions in wildfire-certified staff and other essential workers in the same year. 5. In 2024, a group of Montana researchers found that the common quick suppression of low and modest intensity wildfires actually leads to larger more intense fires. These scientific findings are in line with tradidional tribal fire management practices, based on the knowledge that frequent, low intensity fires on the landscape are not just important to reducing the risk of catastrophic wildfires, but are essential for forest health and resiliency. I am encouraged by the over 60 co-stewardships that were signed in 2024 between Tribal Nations and National Forests. Also in 2024 the Forest Service published a draft amandment to the Northwest Forest Plan, which manages 245 million acres across California, Oregon and Washington. Over half of the amendment involved tribal stewardship. I hope very much that the new Wildland Fire Service at the BLM builds on these partnerships. And as we have great responsibilities, I pray that decisions will be made with the well being of the future generations in mind. Thank you!

I am a resident of Park County, Montana, where more than half of public land outside of designated wilderness is protected by the Roadless Rule. My family, friends and I have spent countless hours hiking, fishing, and camping along Suce Creek, Mill Creek and Deep Creek in the Absaroka Range, Tom Miner Basin and Big Creek in the Gallatin Range, and Big Timber Creek, the Twin lakes, and the Porcupine-Ibex Trail in the Crazy Mountains. I am not alone in my appreciation for these quiet, undeveloped lands. Every year thousands of Montanans, as well as people from around the country and the world, come here to enjoy the hiking, fishing, hunting and wildlife watching available in these roadless areas. These activities are essential to are local economy which relies heavily on tourism and recreation. Rescinding the Roadless Rule will reduce these opportunities and destroy the quiet, undeveloped characteristics of the land that motivates people to come here for recreation. In addition, rescinding the Roadless Rule will especially effect those of us who live in an area prone to wildfires. Building new roads deeper into our forests will increase the chances of fires being started in these areas. 85% of wildfires are human caused and research shows that between 80 and 90% of wildfires start within ½ mile of a road. I urge you to select Alternative 1 (No Action) to keep the 2001 Roadless Rule intact.

Dear Secretary Rollins, I strongly oppose the Proposed Rule rescinding the 2001 Roadless Rule. Our public lands are under attack and it affects every single person in this country. For me - I recreate in areas affected by this decision every week - including but not limited to the Bridger Mountains and the Crazy Mountains. Once we start creating additional impacts to these lands - we can't roll back the impacts. I have devoted my whole life to restoration activities across the landscape that address old scars on the land. The work I do is good and meaningful - but once something gets impacted - it is virtually impossible to bring it back to a pristine state. Please join me in protecting these vital lands in their close-to-pristine state for generations to come. This is the time to do right by the beautiful public lands that give us life, and hope, and peace. Lets keep these lands as they are! Please adopt the No Action alternative for the Final Rule. Sincerely, Elisabeth Bowers Montana

To whom it may concern, I am an outdoor enthusiast from Billings Montana, and I am writing to oppose the proposed repeal of the Roadless Rule. The rule protects nearly 6 million acres of federal land in Montana , including places like the Crazy Mountains and the Beartooth Front near Red Lodge. These lands are the reason many of us live here. I regularly hike and bike in the Beartooths and have backpacked through the Crazy Mountains. These areas and invaluable and need to be preserved in all their glory for future generations. Roadless areas matter for specific, practical reasons: ∙Wildlife and fish. Bull trout spawn mainly in streams within roadless and wilderness areas , and these lands are core habitat for elk, mule deer, and grizzlies. With grizzly management possibly shifting to the states, removing habitat protections now is the wrong move. ∙Clean water. Intact, unroaded watersheds feed the rivers our communities and irrigators rely on. ∙Hunting, fishing, and our economy. Roadless backcountry supports Montana’s outdoor recreation economy and its hunting and angling heritage. ∙Public support. During last fall’s comment period, 99% of more than 625,000 comments opposed rescission , and a University of Montana poll showed broad bipartisan support for keeping the rule . I understand concerns about wildfire and forest health. But the rule already allows thinning and fire-protection work where it’s needed, and building new roads into remote country adds ignition sources, invasive weeds, and long-term maintenance costs the Forest Service struggles to cover today. Blanket repeal is not a targeted solution. Please withdraw the proposal and keep the Roadless Rule in place. If changes are considered, they should be made through a transparent, locally informed process, not wholesale repeal. Thank you for considering my comment. Sincerely, Lindsay Cantwell Billings, MT

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001. 50 years living in NCDE & Yellowstone Region has given me solace based in truth so cannot tolerate rescission in exchange for marketization of public lands. RR means protections not their removal.RR lands mean connectivity for species survival. Rescission displaces threatened species. ESA listed grizzly bear requires best science. Rescission shuns it and will prove fatal for grizzly populations. Cited lands mirror grizzly DPS compliance. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, specifically inventoried RR areas: Lost Water Canyon (9,251 acres), Custer NF, MTBurnt Mountain (10,698 acres), Custer NF, MT Black Butte (871 acres), Custer NF, MT Red Lodge Creek Hellroaring (17,210 acres), Custer NF, MTOkanogan-Wenatchee NF (1,006,000 acres), Okanogan NF, WAGifford Pinchot National Forest (213,000 acres), Gifford Pinchot National Forest, WAMt. Baker-Snoqualmie NF, WALiberty Bell (108,495 acres), Okanogan NF, WACuster Gallatin NF (848,000 acres), Custer Gallatin NF, MTBob Marshall Wilderness Complex (1,483,000 acres),Bob Marshall Wilderness Complex, MT Paine Gulch (7,875 acres), Lewis & Clark NF, MTMt. High (33,484 acres), Lewis & Clark NF, MTMcgregor - Thompson (27,211 acres), Lolo NF, MTDeep Creek (7,669 acres), Lolo NF, MT Trout Creek (30,851 acres), Kootenai NF, MTCataract (9,442 acres), Lolo NF, MTBlue Slide (17,505 acres), Wenatchee NF, WA Mt. Baker-Snoqualmie NF (415,000 acres), Mt. Baker-Snoqualmie NF, WA , Okanogan NF,Pasayten Rim (17,074 acres), Okanogan NF, WASawtooth (15,693 acres), Lewis & Clark NF, MTwin Sisters (13,051 acres), Colville NF, WA Bridger-Teton National Forest (1,417,000 acres), Bridger-Teton National Forest, WyWest Pioneer (248,631 acres), Beaverhead-Deerlodge NF, MTBear - Marshall - Scapegoat - Swan (344,022 acres), Lewis & Clark NF, MT Bob Marshall-Scapegoat-Swan (334,275 acres), Flathead NF, MT East Pioneer (145,082 acres), Beaverhead-Deerlodge NF, MTWest Big Hole (133,563 acres), Beaverhead-Deerlodge NF, MTMadison (127,859 acres), Gallatin NF, MTSelway-Bitterroot (114,953 acres), Bitterroot NF,MTHoodoo (105,162 acres), Lolo NF, MTAllan Mountain (104,184 acres), Bitterroot NF, MTSnowcrest Mountain (97,649 acres), Beaverhead-Deerlodge NF, MT Freezeout Mountain (97,305 acres), Beaverhead-Deerlodge NF, MT Middle Mtn. / Tobacco Roots (96,487 Beaverhead-Deerlodge NF, MTTuchuck (17,730 acres), Flathead NF, MTThompson Seton (52,235 acres), Flathead NF, MTMt. Henry (13,603 acres), Kootenai NF, MTOlympic National Forest (86,000 acres), Olympic National Forest,WASapphires (66,619 acres), Beaverhead-Deerlodge NF,MTBear Creek (8,123 acres), Beaverhead-Deerlodge NF, MT MTLittle Bighorn (133,949 acres), Bighorn NF, WyoSleeping Child (x1074) (21,433 acres), Bitterroot NF, MT, Bitterroot NF, MTDry Canyon Breaks (4,821 acres), Colville NF, WANorth Absaroka (21,063 acres), Custer NF, MTCrazy Mountain (82,093 acres), Gallatin NF, MTBridger (45,059 acres), Gallatin NF, MTHyalite - Porcupine - Buffalo Horn Wilderness Study Area (143,991 acres), Gallatin NF, MTGallatin Fringe (51,571 acres), Gallatin NF, MT Cabin Creek Wildlife Management Area Ocd (35,048 acres), Gallatin NF, MTWAHellgate Gulch (16,821 acres), Helena NF, MTBig Snowy Mountains Wsa (88,003 acres), Lewis & Clark NF, MTCastle Mountains (29,409 acres), Lewis & Clark NF, MT Crazy Mountains (24,942 acres), Lewis & Clark NF, MT Box Canyon (12,584 acres), Lewis & Clark NF, MT- Big Snowies (9,258 acres), Lewis & Clark NF, MT North Fork Smith (8,444 acres), Lewis & Clark NF, MT Tenderfoot - Deep Creek (85,614 acres), Lewis & Clark NF, MT Eagle Park (5,912 acres), Lewis & Clark NF, MT- Calf Creek (10,108 acres), Lewis & Clark NF, MT- Pilgrim Creek (44,608 acres), Lewis & Clark NF, MT Highwood Baldy (15,305 acres), Lewis & Clark NF, MT Highwoods (24,378 acres), Lewis & Clark NF, MT- TW Mountain (8,388 acres), Lewis & Clark NF, MT Granite Mountain (10,338 acres), Lewis & Clark NF, MT Lewis & Clark NF, MT Middle Fork Judith Wsa (81,131 acres), Lewis & Clark NF, MT Bluff Mountain (38,060 acres), Custer NF, MtLine Creek Plateau (24,825 acres), Custer NF, MT, Custer NF, Mt Shoshone NF, WyoWilderness Study Area (51,961 acres), Targhee NF, Wyo- West Slope Tetons (47,448 acres), Targhee NF, Wy- Silver King (64,289 acres), Beaverhead-Deerlodge NF, Montana, - Selkirks (95,967 acres), Idaho Panhandle NF, Idaho-Grizzly Peak (7,441 acres), Kootenai NF, Montana I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects threatened species and of climate change.I ask that the agency respond to each of them.I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Dan Sullivan Chanhassen, MN

My name is Brad Wilson, Founder of Friends of the Crazy Mountains, a grassroots group based in Wilsall, Montana. I support Alternative 1 — the No Action Alternative for the Roadless Rule. WHY NO ACTION IS THE RIGHT CHOICE FOR THE CRAZY MOUNTAINS The Crazy Mountains are a small, pressured, and ecologically important range. Their high ridges and basins hold the headwaters that sustain our ranches and towns. Roadless slopes provide winter range and migration corridors for elk and other wildlife, cold clean water for native trout, and quiet backcountry that families and visitors rely on. Keeping the Crazies roadless protects the natural character that supports our livelihoods, our outdoor traditions, and the long‑term health of the watershed. Because the Crazies are heavily checkerboarded and already fragmented, the remaining intact public lands are especially vulnerable. Roadless protections are one of the few tools that reliably maintain what’s still whole. Rising development interest, land exchanges, and high‑value land sales are already reshaping the range. Removing roadless safeguards increases subdivision potential and speculative value, accelerating consolidation around public parcels. When private holdings tighten around public land, the public’s practical ability to reach those places diminishes, even when legal rights remain. Rescinding the Roadless Rule doesn’t just change management — it changes ownership patterns. In the Crazies, that means more privatization, more buy‑ups, and fewer places where the public can still walk into a truly wild mountain range. WHY NO ACTION IS THE PRUDENT CHOICE FOR NATIONAL FOREST LANDS Roadless areas across our national forests protect clean water, wildlife habitat, and rural communities in ways that built infrastructure cannot. Intact forests reduce erosion, safeguard drinking and irrigation water, and lower costs for downstream towns and ranches. They maintain the large, undisturbed habitat blocks that wildlife need to migrate, breed, and persist, while avoiding the fragmentation and increased human‑wildlife conflict that new roads bring. Roadless landscapes also support natural fire regimes by limiting human‑caused ignitions and slowing the spread of invasive plants. They sustain low‑impact recreation that fuels local economies without creating expensive, long‑term road maintenance liabilities. Choosing the No Action Alternative preserves these ecological and economic benefits, avoids unnecessary taxpayer expense, and keeps forest management focused on stewardship rather than expanding infrastructure. Please adopt Alternative 1 — No Action — to keep our public forests healthy, connected, and accessible for future generations.

Danielle Frevola Missoula, MT October 4, 20206 U.S. Department of Agriculture U.S. Forest Service Re: Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule (Special Areas; Roadless Area Conservation, 91 FR 53827) To Whom It May Concern: I am writing to oppose, in the strongest terms, the proposed rescission of the 2001 Roadless Rule. The Department justifies the proposal by citing wildfire risk, forest health, and the need for local flexibility.[1] The evidence does not support these claims, and I urge you to withdraw the proposal. Wildfire. The Roadless Rule does not stand in the way of fuels reduction; it expressly permits wildfire prevention, suppression, and hazardous fuels treatment [2][3]. Research shows that wildfire ignitions are denser near roads [6]. Further, the Forest Service’s own data estimates that current roadless areas have been treated for wildfire prevention- about 5 percent since 2014 [1]. Additionally, nearly 120 current and former wildland firefighters have written to Congress in support of the rule [9], corroborating further support for current access for wildfire mitigation efforts. What limits further work is funding, not regulation: the Forest Service already carries a road maintenance backlog estimated at between $5 billion and $9 billion [3][4][9]. Local control. The Department says rescinding the rule would restore authority to local forest managers.[1] But managers already have the flexibility the Department describes. The rule expressly allows wildfire prevention and hazardous fuels reduction,[2][3] and where a state wants a roadless policy tailored to local conditions, there is an established path to one, as Idaho and Colorado have shown with their own state-specific roadless rules.[1] A proposal that truly favored local voices would also seek them out. Instead, the Department has held no public meetings on this rescission, even though the original rulemaking drew 1.6 million comments, about 95 percent in support, and more than 600 public meetings.[3] Tribes, many of which rely on intact roadless forests for hunting, fishing, gathering, and cultural practices, are entitled to meaningful consultation as well.[3][9] Local control means little if the communities that live beside these forests are not heard. Economics. Roadless areas already sustain a substantial recreation economy, including more than 25,000 miles of trails, 8,500 climbing routes, 1,000 miles of whitewater, and 10,000 miles of mountain biking trails nationwide.[3] One analysis reported by the Wyoming Wilderness Association puts the annual value of roadless forests near $25 billion, largely from recreation.[9] Timber, by contrast, is a poor financial bet. Studies reported by that group and by Taxpayers for Common Sense indicate the Forest Service often spends more to prepare and administer timber sales than it earns from them.[9] Building roads into remote, marginal areas would add costs the agency is already unable to meet. Water, wildlife, and climate. Forest Service data show that watersheds in roadless areas are far more likely to be in "properly functioning" condition than those outside them.[3] The rule protects the drinking water supply of 354 municipal watersheds, sparing downstream communities the cost of additional filtration.[3] In Montana, about 34 percent of residents drink water that originates in roadless areas.[4] These lands also provide habitat for hundreds of species listed or proposed for listing under the Endangered Species Act, including grizzly bears and lynx, and they store significant amounts of carbon.[3] Public input. More than 600,000 comments were submitted during the initial comment period, and the Forest Service itself acknowledges that 99 percent opposed rescission.[7] By comparison, the original rulemaking allowed 129 days for public comment, and the 2005 rescission attempt allowed 182.[7] This proposal initially allowed about a month and was extended only to October 6.[8] A decision affecting roughly 45 million acres warrants far more public engagement. Notably, among the alternatives in the Draft EIS, only the No Action alternative preserves roadless protections.[9] Montana. In Montana, the rule protects about 6 million acres, roughly a third of our national forest land. That includes the Beartooth Front, the Bridger Range, the eastern Bitterroots, the Crazy Mountains, and the Swan Range.[4] [Optional: add a sentence about a specific roadless area you use and why it matters to you.] If the goal is to reduce wildfire risk, the Department should fund fuels work near communities and in areas that are already roaded, where it can begin immediately without removing protections. I ask that you retain the 2001 Roadless Rule in full. Thank you for considering my comments. Sincerely, Danie Frevola Frevolad1@gmail.Com **See references in the attached letter

Dear Secretary Rollins, Thank You for your time to read this letter. Rolling back the Roadless Rule will open Montana landscapes up to the taxpayers that pay for its management. The forests should be used by more than a few hikers. The crazy mountains are piled high with beetle kill and blown over trees. The roadless rule has blocked forest management and should be rescinded immediately. Please rescind the roadless rule. Sincerely, Patrick Walker Montana

Dear Secretary Rollins, I strongly oppose the Proposed Rule rescinding the 2001 Roadless Rule. Rolling back the Roadless Rule would open irreplaceable Montana landscapes to large-scale logging, road construction, and other development that would industrialize our national forests. I have spent substantial time in Montana's roadless areas hiking, camping, and fishing around the Great Burn, the Gallatin Range, and the Crazy Mountains as well as in countless roadless areas across Wyoming and Oregon. These places are among the most incredible public lands not only in each state, but in the entire country. For the past 25 years, the Roadless Rule has protected these irreplaceable roadless values while still permitting fire suppression, fuels mitigation, trail maintenance, and other essential forest management activities. It is a fiscally responsible, environmentally sound, multiple-use management tool, and it should remain in place. Please adopt the No Action alternative for the Final Rule. Sincerely, Ms. Maddy Munson Montana

To Secretary Rollins, I oppose the Proposed Rule rescinding the 2001 Roadless Rule. I have great memories of watching a solar eclipse in the summer of 2017 while campion the crazy mountains. Its beautiful place. Please keep our unique and precious Montana landscapes from more development. No more roads! Please adopt the No Action alternative for the Final Rule. Sincerely, Ms. Erica Ayling Montana

My name is Katherine Fazekas. I am a United States citizen, who has lived in Idaho, Wyoming, and Montana over the last four years. I am writing as I strong oppose the rescission of the 2001 roadless rule. I frequently recreate on Forest Service land for hiking, backpacking, fishing, camping, foraging, and more. Some of the places I have recreated could be directly impacted by the rescission of this rule, for example, Campfire Lake in the Crazy Mountains of Montana, where I went on my very first backpacking trip. Here, I fell in love with backpacking, and the state of Montana. Experiences like this have inspired me to work in aquatic ecology and fisheries, to do my best to manage resources in beautiful places. The thought of roads going in to these wild and beautiful places is deeply upsetting. I would be honored if you would take this comment into mind as you make decisions regarding our public lands. Thank you, Katherine Fazekas.

As a an 80 year old with degrees in Biology and Public Health, and as a hiker, backpacker and camper in roadless areas, primarily in Montana, I strongly oppose any changes to the 2001 Roadless Rule that would weaken its scope. While anything can be improved, there is no indication now or in recent years, that a review of this rule would result in anything but negative consequences for the remaining undeveloped portions of our national forests. My activities over decades in national forests, wilderness areas and other roadless country in Montana gave me astounding beauty, intimate connection with nature and wildlife, and a peaceful respite from our busy 20th and 21st century lives. The benefit of these areas to human beings only grows in importance as the world becomes more developed, ever more noisy, chaotic. The quiet and beauty of the natural world soothes, and creates an environment in which we can closely observe the patterns of nature and how we are an integral part of it. I particularly remember my few encounters within these protected areas - in particular grizzly bears on the Rocky Mountain Front, and a wolverine when we got off trail in the Crazy Mountains. Those were elemental experiences, taking my breath away as I felt myself drawn back in time when our species lived more closely with these animals. I deeply value the wildness of the Rocky Mountain Front, the Pioneers and Tobacco Roots, the Absarokee, even the Crazy Mountains, albeit a checkerboard of roadless and leased BLM land. Without the protections of roadless areas within these ranges, we would lose so much - carbon sequestration in the forest canopies, the cohesion of the ecosystem allowed to evolve according to its original design, the habitat for our emblematic species - Bear, Moose, Elk, Wolverine, Wolf -, the protection of the watershed, the springs, creeks, streams that converge to form our largest river systems, from Columbia to the Missouri and on to the Mississippi. This is a high price to pay for allowing more logging roads where there are marginal timber resources. Also the claims that more roads and logging would reduce wildfire risk are not only unfounded and unverified. The majority of our huge wildfires of late have been caused by humans, or sparks from their cars on back woods roads. I have also closely observed old stands of second growth fir and cedar in the Cascades, and can see how their thick coating of bark would protect them in a blaze. There are other reasons not to revise or repeal this rule. The existing road network carries billions of dollars in maintenance backlog. It is irresponsible to add to that. Roadless national forests are intact and filter water naturally, providing clean drinking water to millions of Americans. Roadless national forests contain old growth stands that store significant amounts of carbon I have two grandsons, and want them to have the experience of a wild country. I experienced that when I first croed into Montana in 1965. I had spent my first 19 years in Los Angeles and watched the city expand in all directions, rivers with concrete banks, land consumed by shopping centers, freeways and developments. I was young and had no particular judgments; I was just noticing. But something deep in me changed as I dropped into the Centennial Valley, looking across to the Snowcrest and Gravelly Ranges, down along the Red Rock River through the open ranch land and into the Big Hole. I understood nature, the patterns of the work growing crops or feed, the seasons, the growing cycles, and how I fit into it all. I felt I was Home for the first time. The immediacy of this feeling is still with me six decades later as one of the most important experiences of my life. It situated me in the world, in this country, within the landscape. I was no longer separate, walking above the ground, a barrier between the earth and me. It was grounding. I was grounded All humans need to feel connected to what supports them, to see ourselves as part of and perhaps responsible for the earth that gives us life - oxygen, sustenance, water, clothing, shelter. We can find this in wildness, be it National Forests, Wilderness, Roadless Areas, free flowing rivers, the shore, a dark star-lit sky. We are lucky to be a large country where so much of it is still open. Let’s keep some of it that way. There are plenty of areas of public lands that have roads and other amenities to provide other types of recreation and access. In closing, I strongly ask the Forest Service to reject any revision, repeal or weakening of the 2001 Roadless Rule. We as a people, who have a say in governmental decisions, need these lands to be protected so that wildlife habitat, clean water, recreation, solitude and yes, connection with the earth can be there for generations moving forward. Thank you for this opportunity to speak on this important issue - in support of the many wild places that I have grown to love.

To USDA - I am writing to select Alternative 1 and keep the 2001 Roadless Rule intact. I live in Park County, Montana close to the Crazy Mountain range. My family and backpack and hike in the Crazy Mountains every summer and some our most favorite memories are fishing and sitting by the alpine lakes watching the mountain goats. The Roadless Rule is very important for these mountains as they are very vulnerable to development due to the already checkerboard nature of private and public lands. The Crazy Mountains also are the source of water for our land and animals and mining, logging or other development could severely impact the watershed. Building roads into these and other roadless areas may only increase the risk of fires. Most fires are started by humans a 1/4 of a mile from a road and the Roadless Rule already allows hazardous fuels reduction and emergency access. The 2001 Roadless Rule helps keep areas of this beautiful country not only wild but healthy and available to those who want to share that with their children. Whether it is fishing, hunting, sitting under the stars we need to protect these roadless areas for future generations.

Please do NOT remove the 2001 Roadless Area Conservation Rule that has protected public land for the last 25 years. Removing this rule would be another step for the wealthy to start taking public land away from the public. This reminds me of the 2025 land exchange that the U.S. Forest Service made with the Yellowstone Club which basically cut off access to most of the Crazy Mountains in Montana. Allowing more roads to be cut into National Forests will increase wildfire threat, degrade trout streams, open land to possible contamination and open up more flood runoff concerns. Montana continues to rely on National Forests for recreation, hunting and tourism economic gain; but giving more access to the National Forest through roads will ruin the experience for most and terrifies lifetime Montana residents like me. Please re-consider removing this rule. Regards, Brian T. Buckley