Read the comments.

To the USDA Roadless Rule Team: As a Coloradan, and a wildlife enthusiast, I believe the 2001 rule is the single most important land management instrument and the threat of its removal is not only catastrophic but infuriating. Every year, I take a fall trip to explore these beautiful mountains and every year I am left with wonder. Seeing new wildlife, a new sunset, a new plant, a riverbed - it never ceases to amaze me. The protection of these ecosystems are imperative for us, but also for all. Being able to backpack through these undisturbed mountains and connect with other life is one of the few things that bring me joy and peace in such a hectic world. Roads end that possibility. Regarding the Mount Antero in the Pike & San Isabel NFs- Alpine and Subalpine Climate Refugia Connectivity — The area spans from 13,600 feet to 14,276 feet across multiple subalpine and alpine ecosystem types—Rocky Mountain subalpine spruce-fir forest, alpine tundra, and bristlecone pine woodland—creating an intact elevational gradient that allows species to shift their ranges as climate conditions change. This vertical connectivity is critical as warming temperatures push suitable habitat upslope; species dependent on cool conditions can only persist if they can move continuously to higher elevations without fragmentation. Road construction fragments this gradient by creating edge effects, altering microclimate through canopy removal, and introducing invasive species along disturbed corridors, which would trap populations in lower-elevation refugia that are becoming increasingly unsuitable. DEIS Narrative Exceeds the 150-Page Statutory Limit With No Extraordinary-Complexity Determination on the Record The Draft EIS exceeds the statutory page limit and contains no determination authorizing it to do so. Volume I of the Draft EIS is 333 pages. Its narrative text runs from the Introduction at page 9 through page 248. References Cited occupies pages 249 through 285, and the List of Appendices and Appendices 1 through 5 occupy pages 286 through 333. Excluding citations and appendices, as the statute directs, the environmental impact statement is therefore approximately 240 pages long. The applicable limit is 150 pages. 42 U.S.C. 4336a, enacted by the Fiscal Responsibility Act of 2023, limits an environmental impact statement to 150 pages excluding citations and appendices, and permits 300 pages only where the proposed agency action is of extraordinary complexity. USDA's NEPA procedures implement the same limits at 7 CFR 1b.7(a) and (i). The Draft EIS expressly adopts those procedures, stating at page 9 that the Forest Service "has prepared this draft environmental impact statement (EIS) in compliance with the National Environmental Policy Act (NEPA) and other relevant laws and regulations," and that "all references to 7 CFR 1b within this document refer to the interim rule." The document therefore exceeds the 150-page limit by approximately 90 pages. The only lawful basis for an environmental impact statement of this length is a determination that the proposed action is of extraordinary complexity. Volume I contains no such determination. The phrases "extraordinary complexity," "page limit," and "Fiscal Responsibility Act" do not appear anywhere in the document, and 42 U.S.C. 4336a is cited nowhere in it. The Draft EIS asserts compliance with "other relevant laws and regulations" while exceeding the one quantitative constraint those laws place on the document itself, and without invoking the exception that would authorize the excess. This is not a matter of formatting. The page limit operates together with 7 CFR 1b.7(i), which directs that issues not of a substantive nature receive the briefest possible discussion. A ceiling of 150 pages applied to a rescission affecting approximately 44.7 million acres of National Forest System lands compels the agency to compress its effects analysis, and the extent of that compression depends directly on which ceiling the responsible official was working to. A document written to 150 pages must omit substantially more analysis than one written to 300. The public reading this Draft EIS cannot tell which constraint shaped it, because the document never says - and the difference is roughly 90 pages of effects analysis across 44.7 million acres. I request that the responsible official make and document the extraordinary-complexity determination required by 42 U.S.C. 4336a and 7 CFR 1b.7(a) as the predicate for a Final EIS exceeding 150 pages, or, if no such determination is made, that the Final EIS text comply with the 150-page limit. Under 7 CFR 1b.7(f)(3), the response to this comment should cite where in the Final EIS or the supporting proposal record that determination is accounted for. A rule that has survived twenty-five years, multiple administrations, and repeated judicial review deserves more deference than this. CommentID: RLC-20261006-9WBQV3

The Rocky Mountain Elk Foundation appreciates the opportunity to provide the attached comments regarding the proposed USFS Roadless Rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Colorado holds 4,407,277 acres across 326 inventoried roadless areas, and the people of this state have made clear what those landscapes mean to them. Ninety-three percent of Colorado's residents watch wildlife, most of them every day. They understand that abundant, healthy, well-managed wildlife populations improve quality of life, and that well-planned conservation and protection of natural resources makes Colorado a great place to live, work, and recreate. I share that view, and it is the foundation of this comment opposing the proposed rescission of the 2001 Roadless Area Conservation Rule. The Pike-San Isabel National Forest holds two of the roadless areas I am writing through: Old Monarch Pass, at 19,531 acres, and Porphyry Peak, at 3,394 acres. Old Monarch Pass already provides access through a backcountry road experience. Another road would not provide a different experience, and the case for protecting the Pike-San Isabel from unnecessary development does not require elaboration beyond that. At Porphyry Peak, Colorado's high mountain tundra is easily damaged by vehicle traffic across sensitive tundra plants, and off-roaders in this state already have a wealth of places to pursue motorized activities. The 3,613-acre Dorsey Creek area in the Rio Grande National Forest sits at the headwaters of drainages that supply clean water downstream. Colorado is the headwaters for much of the nation, and clean, clear streams like Dorsey Creek provide a resource we simply cannot live without. Across the Rocky Mountain region, 325 municipal water intakes sit in watersheds containing affected roadless areas. The agency must explain, specifically and directly, what this rescission means for the integrity of those watersheds and what substitute protections, if any, it proposes. The agency's own language undermines its stated justification on wildfire. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask the agency to explain why the proposal departs from that prior finding, and to reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is equally difficult to sustain on the agency's own numbers. The record acknowledges: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, all while the existing road system carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with those figures and explain how expanding a system it cannot afford to maintain serves the public interest. The legal history here is not favorable to rescission either. The agency's own record recounts that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That dissatisfaction was tested in court, and the state-by-state approach that replaced the national rule was struck down. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time this substitution was attempted. On the question of statutory authority, the Tenth Circuit has already spoken: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court held the 2001 rule was within the authority Congress granted and did not create de facto wilderness. The agency must explain the legal basis for any contrary position. We don't need more roads. We need more Wilderness. The agency should respond to each of the concerns raised here and place those responses in the public record before any final action is taken. Sincerely, John Koshak Penrose, CO

Re: Docket FS-2025-0001 (RIN 0596-AD66) – Opposition to Rescission of the 2001 Roadless Area Conservation Rule I am writing to oppose the proposed rescission of the 2001 Roadless Rule. Preserving the great outdoors is fundamental to our national identity. Generations before us set aside national forests for our enjoyment, stewardship, and protection. The proposed rescission threatens wildlife and water resources, and it abandons the conservation legacy of leaders such as President Theodore Roosevelt. The Forest Service's own research underscores what is at stake for water. According to the Rocky Mountain Research Station, "forested watersheds supply drinking water for over 80 million Americans, making forests one of the nation's most important forms of natural infrastructure." The same research notes that these data "help identify where forest management can reduce risks and costs for downstream water users." Opening roadless areas to new road construction and timber harvest, which can affect water quality downstream, should not proceed without a clear accounting of those risks to drinking water supplies. By USDA's own estimate, about 18.2 million acres would become eligible for new permanent roads where current forest plans allow them. USDA also reports that most Tribal governments consulted oppose the rescission. To preserve these lands for future generations, the Roadless Rule must remain intact. Source: USDA Forest Service, Rocky Mountain Research Station, research project on forest water supply, value, and future risks to U.S. water resources: https://research.fs.usda.gov/rmrs/projects/water-forests-supply-value-and-future-risks-us-water-resources

I am opposed to repeal of the roadless rule because I frequently recreate in National Forests that will be effected and recreation with the current amount of roads is completely sufficient to fulfill more than a lifetime of recreation in these places. It is worth noting that I often recreate in my overlanding vehicle, which is a 2021 Chevrolet Silverado 2500 with an AT Overland Atlas camping topper that is specifically designed for overloading, which is exploring backcountry roads (primarily in national forests) and camping. I often string together trips of 2-5 days overloading in various national forests. (I will provide my experience doing so at the end of this comment.) Due to the plethora of road options already available in National Forestland, which is enough to satisfy a lifetime of use, the addition or more roads is not a compelling rationale for this proposal. Specifically, these are the reasons I am opposed to repeal of the roadless rule. 1. Impact on nearby National Parks: National Forests play a critical role in the National Park System by often surrounding National Parks and thus serving as a buffer between pristine parkland and wilderness areas and human activity. This is the case for nearly all the major parks in the park system, including the Crown Jewels of the National Parks Service, which will be directly impacted by the recession of the roadless rule—Yellowstone, Grand Teton, Glacier, Mount Ranier, Yosemite, North Cascades, Olympic, Everglades, Grand Canyon, Rocky Mountain, Sequoia and Kings Canyon, Redwood, Crater Lake, Shenandoah, Wrangell St. Elias, and Great Smokey Mountains. It is additionally the case for lesser known, but still important, national parks such as Theodore Roosevelt, Badlands, Guadalupe Mountains, Lassen, Pinnacles, Voyaguers, Mesa Verde, Black Canyon of the Gunnison, New River Gorge, as well as other national park units such as Pictured Rocks National Lakeshore and Sleeping Bear Dunes National Lakeshore. The impact on the Greater Yellowstone Ecosystem looks particularly acute. The GYE, which includes Yellowstone National Park, Grand Teton National Park, and several impacted National Forests — Custer-Gallatin NF, Shoshone NF, Bridger-Teton NF, Caribou-Targhee NF. Like the other National Parks mentioned above, Yellowstone greatly benefits by being completely surrounded by National Forest land. In fact, also like many of these other National Parks, it is impossible to enter Yellowstone without passing through a National Forest. Simply put — increasing roads and industrial motor vehicle traffic in national forestland will adversely impact the ability of people to get into the parks and will have an adverse effect on nearby wildlife and wilderness areas. 2. Impact on last remaining intact ecosystems Personally, when I camp and backpack, I do it in an intact ecosystem. Whether in/around Yellowstone, Tongass NF, Chugach NF, Superior NF / Boundary Waters, or other roadless wilderness areas, these areas are few and far between and provide solitude that is simply unavailable in forestland that permit roads. The personal benefits to me, my family, and my friends are significant. These areas provide time and space and silence for personal reflection and personal growth. Adding additional roads into roadless areas threatens this recreation. It is also worth noting that these areas are some of the last areas WITHOUT ROADS in the world, so the only areas that permit space for reflection away from modern society. These areas need to be preserved as is for this unique and limited experience. The estimated loss of $6.1M annually is a ridiculous underestimate that completely lacks support. The real total is far greater. 3. No definition of the “regulatory burden” that will allegedly be relieved. There is no real definition of what the exact “regulatory burden” that USFS claims is present. If this is just another way of stating that this current government just doesn’t like the rule, then that is not a persuasive reason to repeal it. Moreover, the rationale is full of vague, undefined justifications that do not hold up to scrutiny: - “Constrains responsible officials from exercising the timely, place-based discretion…” - “Evolving national priorities and changed conditions…” - “Removed important management tools for key areas…” - “Unique ecological, economic, and social needs of their communities…” These are vague, boilerplate terminologies for which no concrete examples are given in the rationale. Indeed, there are no examples given of any local forest service officials expressing desire for more “flexibility to address conservation and resource issues” by repealing the roadless rule. Absent any examples, the rationale for this repeal cannot stand. (To be continued - 1 of 2)

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 As an avid hiker, biker, camper and nature photographer, I am deeply concerned about the proposal to rescind the Roadless Area Conservation Rule. The forested areas protected by the Roadless Area Conservation Rule are safehavens for species of plants and animals that cannot survive without protection. Additionally, they provide clean water, fresh air, and quiet, peaceful places for people like me to get away from the chaos of daily life. None of those things can be replaced once ruined. Gutting the few truly natural places we have left will rob us and our children of the biodiversity and ecological stability these places provide. Worse yet, opening up these protected areas to roads will increase the likelihood of human-caused wildfires by nearly five times. "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Furthermore, a 2020 study from the Rocky Mountain Research Station shows that "roads are strongly associated with the spread of invasive plant species in national forests. Non-native plants are twice as common within 152 meters (500 feet) of a road as farther away. Speculation that eliminating road prohibitions would improve forest health is not supported by nearly twenty years of monitoring data." We must prevent this from happening! These forests, once opened and roaded, will not return to what they are now. The biodiversity and ecological stability they carry cannot be reconstructed after the fact. The agency has data in its own record showing that road access drives ignitions upward! None of the above issues have been reconciled with the rescission proposal. I ask that the agency address each of these points, in writing, in the final record. Sincerely, Krista Espinoza Newburgh, NY

I am a former USDA Forest Service employee, a backpacker, hiker, and frequent user of public lands, and I am vehemently opposed to rescinding the 2001 Roadless Rule. A USDA FS study by Sean Healy, "Long-term forest health implications of roadlessness" in 2020 from the Rocky Mountain Research Station found that increasing roads does not increase fire management, and spreads invasive plant species. The taking away of the Roadless Rule will also encroach on Native American sovereignty and access to their ancestral lands, including sacred sites, and have countless negative reverberations. It will also result in long, costly lawsuits - and I would know, as I was an employee on the most litigated National Forest in the United States of America, the Helena National Forest. As it is, more road building would mean more road maintenance, and per the USDA FS 2026 Q2 Fiscal Report, there is already over $6 billion dollars of deferred maintenance on our roads alone - and a backlog of over $11.4 billion dollars of deferred maintenance in total. The Center for Biological Diversity released a report in August 2026 that notes that rescinding the Roadless Rule would put almost 7.5 million acres of endangered animal's habitat at risk, alongside 1,500 miles of creeks, streams, and rivers, at risk for contamination by sediment and other pollutants. National Forest water sources provide drinking water for millions of Americans. I love being a Montanan, hiking on National Forest lands in one of the most intact wilderness states in the lower 48, sharing my world with wolverines, grizzly bears, wolves, and countless other species, flora and fauna alike, who would be threatened and stressed by road incursion into their habitat. Americans do not have much in terms of patrimony to be proud of. We do not have affordable healthcare. We do not have affordable college, or childcare, or family leave, and our federal minimum wage is still $7.25. In Montana, we have had to fight for so long to regain clean water, clean soil, and a healthy environment after decades of intensive resource extraction from mining, timber harvesting, and other industries gutted our land and water. What we do have is our public lands, and our access to them for not just this time but for all time - and not for greed, for enriching private corporations, but for preservation, public use, and for the flora and fauna we are so lucky to live amongst.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I strongly oppose the rescission of the Roadless Area Conservation Rule. I’m writing to protect the forests, the campgrounds, trails and natural landscapes from being mined & logged. I camp & hike in the national forests every weekend to unplug, enjoy nature, connect with my family, and to explore our incredibly beautiful state. What the agency is now proposing to do threatens the things that make that possible, and I oppose this rescission entirely. The wildfire rationale the agency offers for this proposal contradicts the agency's own record. The administration argued opening roadless areas to new roads will improve fuel management and reduce fire risk. The agency's own prior findings state something different: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I have watched what forest roads bring to Colorado forests. Where there are roads, there are people, and where there are people, there are campfires and other fire risks (shooting of firearms & dirtbikes). The roads become heavily used and the natural vegetation along them is quickly destroyed. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for this action is no stronger. The agency's own record contains this admission: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The Forest Service is already $6.9 billion behind on maintaining the roads it has, on a road budget of about $73 million a year. It does not make sense to build more roads when there is not enough funding to maintain the roads that already exist. Additional and unnecessary costs are the last thing the agency needs. The costs continue to outweigh the proposed revenue projected to be generated by building new roads for logging. This is poor financial management. The proposal also argues that state-specific approaches can substitute for the national rule, but the agency has been down that road. The record states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." Colorado's roadless areas are governed by the 2012 Colorado Roadless Rule and sit outside the rescission as proposed, and the honest question the agency has not answered is what, if anything, changes in their management. Beyond Colorado, the agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and must explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time a national rule was replaced with a patchwork of state approaches. And the claimed permitting burden does not hold up either. The existing rule already provides for exceptions: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency should identify which specific burdens are not already addressed by these exceptions, including those for existing mineral leases and community wildfire protection, and quantify them. Across the Rocky Mountain region, including Colorado, 325 municipal water intakes sit in watersheds containing affected roadless areas. We drink water that comes directly from the Rocky Mountains. I am not interested in polluting my drinking water with sediment from timber logging or pollutants from mining operations. Once those pollutants enter a drinking water supply, it is impossible and/or very expensive to mitigate them. The agency held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. National forests are what makes the United States a unique and incredible place to live. Preserving these landscapes for our kids, grandkids, and future generations is responsible stewardship. I urge the agency to withdraw this proposal.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The work I did a few years ago as a research assistant at the Rocky Mountain Biological Laboratory brought me into direct contact with the wild landscapes that the 2001 Roadless Area Conservation Rule protects. These places matter not only for their natural beauty but because they inspire the scientists, writers, and thinkers who will carry that understanding forward. The proposed rescission threatens something I watched generate that kind of meaning firsthand, and I oppose it without reservation. The agency's wildfire rationale for rescission conflicts directly with its own prior findings. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Opening roadless areas to road construction does not reduce fire risk by the agency's own accounting. The DEIS itself reports far higher fire density on roaded land than inside the affected roadless areas. I ask the agency to explain, on the record, why the proposal departs from these prior findings and to reconcile the rescission with the ignition data in DEIS Table 21. The state-by-state approach the agency now proposes has been tried before and was rejected. The record reflects that the USDA discussed "its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That same dissatisfaction led to a state-petition framework that the Ninth Circuit subsequently found deficient. The agency has not explained how this proposal avoids the legal shortcomings identified the last time it tried to substitute local decision-making for a national rule, nor has it addressed its own prior finding that incremental local decisions can erode nationally significant roadless values. How does the agency intend to address those prior deficiencies here? The regulatory flexibility certification accompanying this proposal is not credible on its face. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That conclusion is reached by spreading the projected annual expenditure loss across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the potentially affected roadless areas. The supporting analysis itself concedes that some of those firms may lose those receipts entirely. Averaging away a concentrated impact on identifiable small businesses is not a meaningful flexibility analysis. The agency must withdraw the certification and assess the impact on the entities actually operating in these areas. Finally, the agency invited comment on reliance interests and then declined to assess them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under the standards the Supreme Court articulated in Encino Motorcars and Regents, an agency changing course must grapple with the reliance interests its prior policy created. My own professional development, shaped by work inside landscapes that exist as they do precisely because of twenty-four years of roadless protection, is one such interest. The agency should identify and weigh the reliance interests described in every comment it receives, including this one, before it takes any further action on this rescission. Sincerely, Caleb Boxwell Syracuse, NY

Please keep the Roadless Rule in place. This rule has led to the protection of millions of acres of national forest where my family and I enjoy spending time recreating. We are grateful for the in-tact landscapes that support vibrant plant and wildlife populations. I am a resident of the Rocky Mountain west where wildfires remain a top concern. Research supports that wildfires are more likely to start in roaded areas compared to roadless. I do not want to see my taxpayer dollars spent on road development and road maintenance. The national forests are a key part of the public lands system which supports a massive outdoor recreation industry. Outdoor recreation is a key part of the economy of the state I live in and I want to support rules like the Roadless Rule to protect our industry and foster growth for my state.

Please do NOT rescind the 2001 Roadless Rule. I have lived and worked in the Rocky Mountain West for over 35 years. America’s wilderness is also America’s pride and joy. Selling off this land to the highest bidder will cause pain, grief and suffering that can never be reversed. It is a betrayal of the word patriotism.

Thank you for the opportunity to comment on the Roadless Rule. We live in Pennsylvania. In the Eastern US, few places exist where we can be still awed into wordlessness by a night sky above us. For the last 3 years, we took on what were epic journeys for us, towing our camper across the US to National Parks in the western states where we could pursue a real dark night sky. We visited Devil's Tower, Badlands (SD), Rocky Mountain, Zion, Capitol Reef, Bryce Canyon, Arches, Canyonlands, Theodore Roosevelt, Grand Teton, and Yellowstone. Previous years we flew to Grand Canyon, and Yosemite. While the night skies we very good, many people living in those areas don't recognize what beauty and resource they have, and do not take the care and respect the natural dark and and a naturally dark night sky. We experienced other campers in our National Parks with horrible outside lighting left on all night long while they slept, with no care that someone might value and treasure what was lost because of their careless use of light at night. We literally drove thousands of miles to see a night sky with the Milky Way blazing and not their camper. Yes, I am an amateur astronomer and used to be impressed by and focused on the technical facts surrounding the stars and DSO's. Lately, I have come to realize there is much more. The pure enjoyment of a natural night sky that leads to a state of wordlessness and amazement, akin to what I felt seeing the Tetons on our approach from Dubois, WY. Straight up couldn't speak for 5 minutes or so. Recently, while we all innately know this, the beautiful natural night sky is a resource for mental health and wellbeing. Like forest bathing, an immersive night sky can bring peace and a clear perspective so much that people will pay for an immersive experience under a truly pristinely naturally dark night sky. Our best night under the night sky was near Little Bighorn, at a private campground (7th Ranch) that bordered the National Monument. Night time weather hampered us in Grand Teton and Yellowstone. Even our beautiful Yellowstone site in E Loop had a bathroom with all night lights poorly designed and installed so they severely limited what night sky we could see. Mostly, we are all careless about our lighting. We go to bed and leave the lights on. It is harming our health, our mental state, and causing damage to the natural world around us, especially the one that exists at nighttime. Here in the eastern US, it is very difficult to get people to change their habits. In the western US, where beautiful nights skies exist almost everywhere, people are careless and do not recognize what they have. Ending the Roadless Rule will just allow access to the vanishing pristine areas we still have, that still contain a wild, naturally dark, pristine night sky. Will people and companies be responsible with their lighting (and other anthropogenic impacts)? Historically and sadly, the evidence says we won't be responsible. The problem is, ecologically speaking, when we lose the night, we will lose the day. They are reciprocal entities that need each other to survive. That is what science offers evidence of. Beyond the words and equations of science exists something much, much deeper. It is embedded in our humanity and literally in our DNA. Ending the Roadless Rule will threaten the last precious places where we can find our very soul and find healing from the damages of the modern lifestyle. These precious treasures containing stunning natural areas and pristine night skies are an infinitely valuable balm worth more than the most expensive medicines known to man. Conserving such places is what our calling is and we will be accountable to a higher voice and the generations that come after us if we sell access to these precious treasures for what will profit a man. My vote, with all respect, is not to end the Roadless Rule, as it will bring a ruination of resources that don't belong to us. They belong to the generations and those resources are far more valuable than we can imagine. At Little Bighorn, my wordless moment was, Milky Way from horizon to horizon. To the north was Cassiopeia, which pointed to the Andromeda Galaxy. For the first time in my life of 7 decades and a little, I saw the Andromeda Galaxy with just my eyes. A part of me was healed and a 5000 mile drive was so worth it. Preserve that view so it heals other people, too. Put roads into these areas and we will lose it all. We have roads and access enough to all the resource we need. Keep the Roadless Rule. Thank you. (I included the view from Little Bighorn. It was far better than the camera could capture.)

I am writing to ask that the USFS does not rescind the 2001 Roadless Rule. Inventoried Roadless Areas (IRAs) protect drinking-water supplies for more than 25 million Americans, provide economic benefits through recreation, and can reduce water-treatment costs by protecting high-quality watersheds. The record does not indicate that rescinding the Roadless Rule would reduce wildfire activity. IRAs protect more than 130,000 km of streams and rivers and are the primary protection mechanism for more than 100,000 km of rivers. These protections influence drinking-water supplies for at least 25 million Americans (Olden et al., 2026). Inventoried Roadless Areas in and near Ashley National Forest protect headwaters in the Upper Green River Basin, a major tributary of the Colorado River. Because Colorado River water supports communities and agricultural users throughout the basin and is delivered to Southern California, protecting these headwaters has downstream importance far beyond the forest’s boundaries. Degradation of watersheds leads to degradation of water quality through the loss of forest vegetation, which moderates streamflow and serves as a barrier to water-polluting land uses such as agriculture, development, and logging. Keeping forested areas intact helps keep streams cold, supports aquatic life, and keeps rivers clean, reducing costs to water-treatment facilities and, ultimately, consumers. IRAs overlap substantially with high-demand hunting and fishing areas and support aquatic and terrestrial biodiversity. They also provide connected habitat, summer and winter range, and travel corridors for wildlife. In a peer-reviewed study, Sean P. Healey of the Rocky Mountain Research Station found that IRAs burned at rates broadly similar to the rest of the National Forest System. Contrary to the implication that roadless areas prevent fire mitigation, the study found that IRAs contained about 21% of National Forest System tree cover but accounted for 34% of fuel-treatment activities between 2001 and 2019. The study also found significantly fewer human-caused fires in IRAs. Human activity is responsible for a large share of wildfire ignitions nationwide (Healey, 2020). To prevent severe wildfires throughout the West, it is imperative to sustain resilient ecosystems rather than fragment them with roads. Invasive species such as cheatgrass and other grasses and woody vegetation can outcompete native plants and often contribute to increased fire activity. Just this year, I have been denied access on existing and open Forest Service roads well over a dozen times because of washouts and downed trees. That is in addition to the trees I was able to cut and move to the side of the road to allow travel, which has happened even more often. Why would we build more roads if we cannot maintain the roads we already have? A fiscally conservative approach would focus on maintaining the roads we have rather than building new ones. A 2026 technical white paper estimated deferred maintenance for the National Forest road system at more than $9 billion (WildEarth Guardians, 2026). It does not make sense to spend money building new roads—or arguing for the opportunity to build new roads—when the existing road system has such substantial maintenance needs. Our goal should not be to increase roads. Rather, it should be to maintain the roads we have, prevent the spread of invasive species, protect water quality, and protect wildlife habitat. Roads fragment habitat for both aquatic and terrestrial wildlife. Every deer, elk, and bear I have been lucky enough to take has been in either a wilderness area or an IRA. Roadless areas generally, and IRAs specifically, are islands of connected habitat, summer and winter range, and travel corridors for wildlife. I have had the opportunity to live near and explore several of these exceptional places. I have shared hunting and fishing experiences with my children in these places. My family is fed and watered by IRAs, and I ask, as a citizen in this great republic: please protect roadless areas. “The ‘greatest good of the greatest number’ applies to the number within the womb of time, compared to which those now alive form but an insignificant fraction. Our duty to the whole, including the unborn generations, bids us restrain an unprincipled present-day minority from wasting the heritage of these unborn generations.”

I am writing to ask that the USFS does not rescind the 2001 Roadless Rule. Inventoried Roadless Areas (IRAs) protect drinking-water supplies for more than 25 million Americans, provide economic benefits through recreation, and can reduce water-treatment costs by protecting high-quality watersheds. The record does not indicate that rescinding the Roadless Rule would reduce wildfire activity. IRAs protect more than 130,000 km of streams and rivers and are the primary protection mechanism for more than 100,000 km of rivers. These protections influence drinking-water supplies for at least 25 million Americans (Olden et al., 2026). Inventoried Roadless Areas in and near Ashley National Forest protect headwaters in the Upper Green River Basin, a major tributary of the Colorado River. Because Colorado River water supports communities and agricultural users throughout the basin and is delivered to Southern California, protecting these headwaters has downstream importance far beyond the forest’s boundaries. Degradation of watersheds leads to degradation of water quality through the loss of forest vegetation, which moderates streamflow and serves as a barrier to water-polluting land uses such as agriculture, development, and logging. Keeping forested areas intact helps keep streams cold, supports aquatic life, and keeps rivers clean, reducing costs to water-treatment facilities and, ultimately, consumers. IRAs overlap substantially with high-demand hunting and fishing areas and support aquatic and terrestrial biodiversity. They also provide connected habitat, summer and winter range, and travel corridors for wildlife. In a peer-reviewed study, Sean P. Healey of the Rocky Mountain Research Station found that IRAs burned at rates broadly similar to the rest of the National Forest System. Contrary to the implication that roadless areas prevent fire mitigation, the study found that IRAs contained about 21% of National Forest System tree cover but accounted for 34% of fuel-treatment activities between 2001 and 2019. The study also found significantly fewer human-caused fires in IRAs. Human activity is responsible for a large share of wildfire ignitions nationwide (Healey, 2020). To prevent severe wildfires throughout the West, it is imperative to sustain resilient ecosystems rather than fragment them with roads. Invasive species such as cheatgrass and other grasses and woody vegetation can outcompete native plants and often contribute to increased fire activity. Just this year, I have been denied access on existing and open Forest Service roads well over a dozen times because of washouts and downed trees. That is in addition to the trees I was able to cut and move to the side of the road to allow travel, which has happened even more often. Why would we build more roads if we cannot maintain the roads we already have? A fiscally conservative approach would focus on maintaining the roads we have rather than building new ones. A 2026 technical white paper estimated deferred maintenance for the National Forest road system at more than $9 billion (WildEarth Guardians, 2026). It does not make sense to spend money building new roads—or arguing for the opportunity to build new roads—when the existing road system has such substantial maintenance needs. Our goal should not be to increase roads. Rather, it should be to maintain the roads we have, prevent the spread of invasive species, protect water quality, and protect wildlife habitat. Roads fragment habitat for both aquatic and terrestrial wildlife. Every deer, elk, and bear I have been lucky enough to take has been in either a wilderness area or an IRA. Roadless areas generally, and IRAs specifically, are islands of connected habitat, summer and winter range, and travel corridors for wildlife. I have had the opportunity to live near and explore several of these exceptional places. I have shared hunting and fishing experiences with my children in these places. My family is fed and watered by IRAs, and I ask, as a citizen in this great republic: please protect roadless areas. “The ‘greatest good of the greatest number’ applies to the number within the womb of time, compared to which those now alive form but an insignificant fraction. Our duty to the whole, including the unborn generations, bids us restrain an unprincipled present-day minority from wasting the heritage of these unborn generations.” — Theodore Roosevelt, A Book-Lover’s Holidays in the Open (1916)

Please keep the Roadless Rule in place to protect our wild and pristine spaces. I live in Texas, but I have lived in Colorado, where I frequently visited Rocky Mountain National Park. I have also visited the Pacific Northwest, specifically to see the forests there, and I have taken my child there to see the forests as well. If roads are allowed in these places and we lose them, we also lose the income generated by tourism to these areas. Rescinding the Roadless Rule not only costs us financially in terms of tourism dollars, but these areas become more prone and susceptible to wildfires, which cause enormous loss of resources and habitat, not just for the wildlife that lives there, but also for the humans that live in and around it. Forest fires are a drain on resources and pollute the air and waterways, two things we all need. It also costs money to fight the fires, money that could be spent on other things to benefit the whole of the country. Not only do you lose the tourism dollars, you also pay more to fight the fires that would happen. The American public overwhelmingly supports the Roadless Rule. Members of Congress have also come out in support of the Roadless Rule. It’s been one of the most successful conservation measures put in place. Keeping these places free from roads allows them to remain sustainable. Please do not rescind the Roadless Rule. Thank you for your time.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Watching fire after fire move through my Rocky Mountain homes is disheartening and devastating. I have lived in rural Utah and rural North Dakota my whole life, always near wildlife and near national forest and parks, and what I have seen through those fire seasons shapes every concern I bring to this comment. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that it be withdrawn. The agency's own record is direct about what roads do to fire risk: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission partly on wildfire and fuels management grounds, yet that justification runs straight into the agency's own findings. Utah alone holds 222 inventoried roadless areas totaling 4,013,529 acres. Opening those landscapes to new roads would extend the very ignition-prone infrastructure that the agency's own data, including DEIS Table 21, associates with far higher fire density than exists inside the roadless areas today. The agency must explain why the proposal departs from those prior findings and reconcile the claimed wildfire rationale with what the ignition data actually show. Water is the most important resource we have in the world, and we need to protect our water sources from pollution at all costs. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. Fewer than 12 percent of those watersheds have impaired streams today. That is a record worth protecting, and the proposal offers no credible account of how it would stay that way once road building begins. How does the agency propose to hold sediment loads in check when its own analysis attributes the overwhelming share of timber-sale sediment to roads themselves? The proposal also cannot justify itself on economic terms. The agency's record shows that the total timber volume affected by this rule is, by the agency's own description, "less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Those are marginal gains set against a road system already carrying a $6.9 billion maintenance backlog on a budget of roughly $73 million a year. We already pour enormous resources into maintaining the roads we have. The agency's Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. An analysis whose own range cannot establish a net benefit does not justify expanding infrastructure the agency demonstrably cannot afford to maintain. The agency must reconcile the proposal with those numbers and explain, in specific terms, where the funding for new road maintenance comes from. The proposal argues that state-specific approaches can replace the national rule, but the agency's own prior record records its "dissatisfaction with the Roadless Rule" and its "rejection of the Roadless Rule's 'inflexible one-size-fits-all' nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That dissatisfaction does not answer the question the Ninth Circuit asked the last time the agency tried this, namely whether local decision-making incrementally erodes nationally significant roadless values that no single state-level process can protect. The agency must address that prior finding and explain how this proposal avoids the deficiencies that sank the earlier state-by-state approach. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. Courts already answered that question. The Tenth Circuit concluded: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court held the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must state, plainly and with specificity, the legal basis on which it now reaches a contrary conclusion after a federal appellate court ruled against that position. Sincerely, Desiree Childs Watford City North Dakota

As an avid outdoors enthusiast in Montana, it's hard to overstate the importance of the Roadless Rule. Large roadless landscapes make the Rocky Mountain west the incredible landscape it is, and it affords people like me and my sons an opportunity to experience wildlife and nature in a way we cherish - without traffic! We hunt, fish, and recreate in areas without roads and the quality of those experiences depends on the roadless nature of those landscapes. Please do not repeal the Roadless Rule. Thank you.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Rocky Mountain National Park is one of my holy places, and I am in Michigan's public lands almost weekly. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The agency has framed this proposal partly as a wildfire management measure. Its own record says otherwise. The agency's own draft environmental impact statement states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Michigan holds 6 inventoried roadless areas totaling 16,124 acres. Photographing the biodiversity in places like these, in national forests and parks, is something I do almost every week. These are not abstractions to me. They are places I visit and care about passing to the next generation. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not support this action either. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." To take and extract without studying the impacts is myopic and serves only greed and one sector of our country. That is not managing for what is best for all Americans and the long view. The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency is also already $6.9 billion behind on maintaining the roads it has, against a road budget of about $73 million a year. Roads in natural areas are disruptive and rude. Once made, you cannot go back. How does the agency justify expanding a road system already carrying a $6.9 billion maintenance backlog when its own analysis cannot establish a net benefit from this rescission? The proposal suggests that state-specific approaches can replace a national rule. The record shows the agency has tried this before. The agency's own record acknowledges that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Roadless Rule was a very long and well thought out process. Replacing it with state-by-state management did not survive judicial review the last time it was attempted. Across the Eastern region, which includes Michigan, 286 municipal water intakes sit in watersheds containing affected roadless areas. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified when the agency last took this path. Finally, much of what the agency says the rule prevents, the rule already permits. The rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." This latest move reads as the burp of destruction from those who do not have our natural heritage in mind, not a careful administrative correction. The agency has not identified, with specificity and with numbers, which operational burdens are not already addressed by these existing exceptions. It should do exactly that before proceeding further. These public lands are the best of the best. Just knowing wild places still exist is a thrill and spirit-lifting. The agency must justify this rescission through its own evidence, not in spite of it. Sincerely, M Lorenz Kewadin, MI

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I am a resident of Blacksburg, Virginia. I am particularly concerned about rescinding the Roadless Area Conservation Rule because I am an avid fisherman and spend considerable time fishing the mountain streams of Virginia. More than any other waterway, the clear, rocky mountain streams provide an exceptional angling experience. These streams are not only incredibly beautiful, but they also sustain healthy populations of Virginia’s state fish, the brook trout. Brook trout are highly sensitive to changes in water quality and stream habitat. Increased sedimentation, rising water temperatures, loss of surrounding tree cover, and chemical pollutants can all negatively affect trout populations and can result from road construction and the industrial activities that roads facilitate. For these reasons, brook trout populations have declined across much of their historic range, making the protection of high-quality remaining habitat especially important. Many of Virginia’s remaining pristine brook trout waters are located on lands protected by the Roadless Area Conservation Rule. One of my personal favorite streams to fish is located within a roadless area of the George Washington and Jefferson National Forests. The protection provided by the Roadless Rule helps preserve these streams and their surrounding watersheds from degradation associated with road construction and extractive activities. These lands are valuable not only for ecological reasons, but also for recreation and the economies of rural communities. Anglers travel from across Virginia and the United States to fish for wild brook trout in the Appalachian Mountains. Maintaining high-quality, accessible public lands therefore provides recreational opportunities while supporting local businesses and rural economies. Finally, I am concerned that wildfire reduction is being presented as a justification for rescinding the Roadless Rule. In Virginia, wildfire is not a significant concern, and I do not believe that a nationwide rescission of the Roadless Rule is an appropriate response. If wildfire reduction is the primary justification for changing the Roadless Rule, I believe any changes should be targeted to areas where wildfire poses a significant risk rather than applied uniformly across the entire United States. For these reasons, I strongly oppose the proposal to rescind or alter the Roadless Area Conservation Rule. I instead support Alternative 1, the No Action Alternative, and urge the Forest Service to retain the existing protections for our remaining roadless areas.

Dear Secretary and Chief: My water in Snohomish County, WA comes from the Glacier Peak K Roadless area. The Roadless Rule has protected this watershed since 2001. The proposed rescission would foreseeably degrade conditions in our upstream watershed. I respectfully submit that the 2001 rule should be retained. Spada Lake, the reservoir that gathers the snowmelt and precipitation for our county, is an easy drive from my home. I've stood above it many times. I grew up hiking in Glacier Peak K Roadless Area: Big Four Ice Caves as a kid and now with the next generation of children, or up to Vesper Peak or the other looming peaks of the area. I have boated down the Skykomish River that drains part of Glacier Peak K. My history as well as my water lives here. The taste of clear, cool water from the Cascades is better than any water I've ever tasted. I feel safe knowing this water comes from a roadless area because my family and I won't be exposed to water tainted by mining or sediment. Regarding the Glacier Peak K in the Mt Baker-Snoqualmie National Forest, Washington: The aquatic ecosystems of the Glacier Peak K IRA, Mt Baker-Snoqualmie National Forest, depend on the absence of road-generated fine sediment. Clean gravel substrates support macroinvertebrate production and fish reproduction. Intact riparian canopy maintains the cold water temperatures that govern dissolved oxygen levels and species composition. Roads eliminate both conditions. The combined effect of low infiltration capacity of road surfaces and interception of surface flow and throughflow by cutslopes is increased surface runoff, leading to frequent erosion from the road surface (many events per year) and periodic mass failures from the adjacent hillslopes. The ecological consequences of sediment chronically supplied from roads (press), may be more detrimental than from sediment periodically supplied from post-fire debris flows (pulse). — USDA Forest Service, Rocky Mountain Research Station, 2012 (https://doi.org/10.1016/j.geomorph.2011.06.021) I'm asking from the bottom of my heart – please retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. In earnest, Leah Scott-Zechlin