Read the comments.

Dear Forest Service Leadership: As someone who has lived in a rural community adjacent to roadless national forest for most of my life, I want to offer the Department a simple observation: the rule has done what it was supposed to do, and the case for undoing it is thin. It affects the community in which I live. National Forests and wild places are the lifeblood of our community. Often I spend time in roadless areas. It’s the only time my heart and brain line up to offer any solitude. I once spent a whole day in the backcountry with a very good friend. We had deeper conversation without the distractions. I’d relive it everyday if I could. If this rule is rescinded, I lose drinking water and a public space to exist in nature harmoniously Regarding the Comanche Peak Adjacent Area in the Arapaho & Roosevelt NFs, Colorado: Headwater Protection for the Cache la Poudre River System — This roadless area contains the headwaters of the South Fork Cache la Poudre River and multiple tributary streams (Fall Creek, Fish Creek, Beaver Creek, Buckhorn Creek, Joe Wright Creek) that feed into the Cache la Poudre River—a major water source for downstream communities and ecosystems. The subalpine and montane riparian shrubland ecosystems in Crown Point Gulch, Dadd Gulch, and Black Hollow maintain the cold-water conditions and riparian vegetation structure that regulate stream temperature and sediment load. Removing the forest canopy and riparian buffer through road construction would expose these headwater channels to direct solar radiation and erosion, degrading water quality for federally threatened Greenback Cutthroat Trout populations that depend on cold, clear spawning habitat in these streams. Road construction in Comanche Peak Adjacent Area introduces sediment, alters hydrology, and delivers chemical contaminants to adjacent habitats — the direct physical drivers of 7.2 - Dams & water management/use. The absence of site-specific analysis for Pallid Sturgeon (Scaphirhynchus albus) in the Comanche Peak Adjacent Area Inventoried Roadless Area, Arapaho & Roosevelt NFs, constitutes a gap in the administrative record that exposes the final decision to legal challenge. The DEIS must evaluate 7.2 - Dams & water management/use at the documented severity and scope. "In 2001, the Roadless Area Conservation Rule prohibited road construction and timber harvest in 240,000 km² of inventoried roadless areas (IRAs) located on United States Department of Agriculture Forest Service lands. Many IRAs are among the most wild, undeveloped areas both in the nation and within their respective states. IRAs increase the size of—and reduce isolation between—protected areas, likely buffering them from external stressors. In some places, IRAs protect watersheds that deliver drinking water to hundreds of thousands of people." — Conservation Science and Practice (Wiley), 2020 Keep the Rule. That's the whole comment. With gratitude, Morgan Wetzel

I strongly object to the U.S. Forest Service proposal to rescind the 2001 Roadless Area Conservation Rule. The Roadless Rule wisely blocks roadbuilding, logging, drilling, and mining on 45 million acres of national forests, about a third of our national forest system. This is critical because these lands provide clean air, clean water, important and necessary carbon storage, and critical fish and wildlife habitats including habitats for threatened and endangered species. In Olympic National Forest, where I have worked, hiked, gathered firewood and enjoyed nature, spectacular roadless areas such as Rugged Ridge, Lower Gray wolf, Middle Dungeness, Jupiter Ridge, Lena Lake, South Fork Skokomish and South Quinault Ridge are all well deserving of Roadless Area designation. All of these areas offer protection to upper and middle watersheds including domestic water supplies. All buffer existing wilderness areas, Buckhorn, The Brothers, Mt. Skokomish, Wonder Mountain, and Colonel Bob wildernesses and nearby Olympic National Park, a UNESCO Biosphere Reserve and World Heritage site. And nearly all are included in U.S. Senator Murray's and U.S. Representative Emily Randall’s Wild Olympics Wilderness and Wild and Scenic Rivers Act, currently being considered by Congress. Roadless areas contain less than a quarter of one percent of the nation’s timber and an even smaller fraction of oil and gas reserves. They are more fire resistant than roaded areas, where the majority of fires occur. However this proposal would throw them open to road building and polluting extractive industries for private profit at the public’s expense. The Forest Service's EIS for this project is wholly inadequate and fails to consider the environmental and economic benefits roadless areas provide or the costs incurred in rescinding roadless rule protections. These lands are much more valuable for the public benefits they provide: clean air, clean water, critical carbon storage, fish and wildlife habitats and recreation opportunities for present and future generations than for the meagre and fleeting benefits to be gained by developing them. I endorse the arguments included in Washington Wild's comment letter, which was signed my multiple parties including Olympic Park Advocates, of which I am a long-time member.

I oppose the proposed repeal of the Roadless Area Conservation Rule. I urge you to maintain the existing Rule as is. The Roadless Rule protects the watersheds of many of our National Wild and Scenic Rivers in California, as well as many rivers and streams deemed eligible for national protection by the Forest Service. The roadless areas through which these wild rivers flow are an important refuge for threatened and endangered fish, wildlife, and plants. They provide outstanding opportunities for outdoor recreation in a primitive setting, such as hiking, backpacking, whitewater boating, mountain biking, and even motorized recreation on existing legal trails. Roadless areas provide clean water for wildlife and recreation and the rivers that flow from the roadless areas into reservoirs are an important source of high-quality water for downstream communities and farms. Many rivers to consider include but are not limited to the North Fork American, Rubicon, Mokelumne, Tuolumne, South Fork Kings, Middle Fork Feather, and North Fork Kern. The Roadless Rule does not limit public access. Most roadless areas are legally available for public recreation under the Rule – they are simply closed to new road building, commercial logging, and other development that requires new roads. It is not true that roadless areas increase wildfire threats. Roads – not roadless areas – are a primary source of wildfire starts. With 30+ years as a career wildland firefighter I have direct knowledge of how many fires are cause by humans, especially when they have easy access to forested areas by vehicle. Please go into the Dept of Agriculture (Forest Service) and Dept of Interior’s “wildfire cause” GIS data and plot it on maps. It is a quick & easy visual of human caused fire with a direct correlation to roads. I have direct knowledge that it is still possible to reduce hazardous fuels (in order to reduce wildfire risk) in Roadless Areas, without repealing the Rule. I have been an author, editor, and fire/fuels specialist on several hazardous fuels reduction environmental analysis projects and implementation of those NEPA projects within Roadless Areas. So please do NOT spin this repeal as a way to reduce wildfire risk when there are other tools (besides logging) to complete this work that already exists. Which brings me to my next comment. Heavy equipment also causes wildfires and bring risk to the roadless areas if used for logging operations. I have responded to many equipment caused fires outside of roadless areas both as a fire fighter and as a fire investigator. All you have to do is pull the “wildfire cause” GIS data to see this fact. I urge that Roadless Rule be retained to protect our wild places for recreation, fish and wildlife habitat, and as important sources of clean water for our communities and farms. Sincerely, Teresa Riesenhuber Sincerely, Teresa Riesenhuber Somerset, CA 95684

I oppose the proposed repeal of the Roadless Area Conservation Rule. I urge you to maintain the existing Rule as is. The Roadless Rule was intentionally enacted for good reason. It protects the watersheds of many of our National Wild and Scenic Rivers in California, as well as many rivers and streams deemed eligible for national protection by the Forest Service. The roadless areas through which these wild rivers flow are an important refuge for threatened and endangered fish, wildlife, and plants. The Roadless Rule provides greater continuity of habitats to increase local biodiversity and minimize risks of invasive species by limiting the edge effect for habitats and habitat alteration due to resource extraction. Roadless Areas provide outstanding opportunities for outdoor recreation in a primitive setting, such as hiking, backpacking, whitewater boating, mountain biking, and even motorized recreation on existing legal trails. Roadless areas provide clean water for wildlife and recreation. The rivers and the headwaters and tributaries of those rivers that flow from and through the roadless areas into reservoirs are critical to maintaining high-quality water for downstream communities and family farms and agriculture. Many rivers to consider include but are not limited to the Klamath, South Fork Trinity, North Fork American, Tuolumne, South Fork Kings, Middle Fork Feather, Merced, and North Fork Kern. The Roadless Rule does not limit public access. Most roadless areas are legally available for public recreation under the Rule – they are simply closed to new road building, commercial logging, and other development that requires new roads. Roadless areas do not increase wildfire threats. In fact, it is quite the opposite because roads, not roadless areas, are a primary source of wildfire starts. The Forest Service has current techniques, tools, and existing access to address any fire concerns within the roadless aresa. Natural areas with less disturbance, such as Roadless Areas, are better equipped to deal with normal fire occurrence with more resiliency and allow fire to return nutrients to the land instead of burning catastrophically. I urge that Roadless Rule be retained to protect our wild places for recreation, fish and wildlife habitat, to protect our wild and scenic rivers, and be retained in their current status as important sources of clean water for our communities and farms. Sincerely, W. Y.

Brooke L. Rollins and Tom Schultz, I am a masters student at Colorado state university studying ecosystem science and sustainability with a focus on water resources. I am also a business owner that advocates for better water quality for all. I strongly oppose any changes to the roadless rule because it will destroy our source water supply and decrease water quality for the Cache la Poudre river basin. Hundreds of thousands of people rely on this clean water! As a researcher, I have studied this area and seen the impacts that land change can have on the landscape and to our water quality. It is detrimental that this administration prioritizes the health of the people and the land. Water is needed for every human being on this planet and if that water is degraded, nothing can survive. If this rule is rescinded, the area that I have studied and recreated in will be destroyed along with our source water supply. The animal populations, healthy forests, and the people that live in and around this area will be threatened. It will also increase the chance of wildfire risk in the area. It is known that the majority of wildfires start from roads. Regarding the Comanche Peak Adjacent Area in the Arapaho & Roosevelt NFs, Colorado: Headwater Protection for the Cache la Poudre River System — This roadless area contains the headwaters of the South Fork Cache la Poudre River and multiple tributary streams (Fall Creek, Fish Creek, Beaver Creek, Buckhorn Creek, Joe Wright Creek) that feed into the Cache la Poudre River—a major water source for downstream communities and ecosystems. The subalpine and montane riparian shrubland ecosystems in Crown Point Gulch, Dadd Gulch, and Black Hollow maintain the cold-water conditions and riparian vegetation structure that regulate stream temperature and sediment load. Removing the forest canopy and riparian buffer through road construction would expose these headwater channels to direct solar radiation and erosion, degrading water quality for federally threatened Greenback Cutthroat Trout populations that depend on cold, clear spawning habitat in these streams. Sediment generation. Forest roads generate substantially more sediment than undisturbed forest. A heavily used gravel road segment in the Pacific Northwest delivered roughly 130 times more sediment than an abandoned road, and paved segments yielded less than 1% of the sediment from gravel surfaces (Reid & Dunne 1984; Sugden & Woods 2007). — Reid & Dunne, 1984 (https://doi.org/10.1029/WR020i011p01753); Sugden & Woods, 2007 (https://doi.org/10.1111/j.1752-1688.2007.00016.x) Rescinding the Roadless Rule would open the Comanche Peak Adjacent Area, Arapaho & Roosevelt NFs to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. The forest service is well aware of the impacts that this will have on our water and land. The forest service needs to protect public land and stop bending over backwards for the people in power to make a quick buck. It is not in the best interest of the people of the United States of America or our public land that we fought for! My comments are respectfully submitted in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. With respect, CommentID: RLC-20261006-X32Z3G

Dear Secretary: I'm writing as an American with a strong belief in public lands. Regarding the South Mills River in the Pisgah National Forest, North Carolina: Headwater Protection for Aquatic Species Dependent on Cold, Clean Water — The South Fork Mills River originates within this roadless area and flows through multiple tributary systems—Bradley Creek, Cantrell Creek, and Clawhammer Creek—that collectively form a Priority Watershed designated by the U.S. Forest Service for restoration and protection. The Eastern Hellbender, a proposed federally endangered salamander, depends on the undisturbed streambeds and cold water temperatures maintained by the intact forest canopy in this area. Road construction would remove streamside vegetation, allowing solar radiation to warm water and destabilize banks, directly degrading the specific habitat conditions this species requires to survive. Salmonid embryo survival. Fine sediment in spawning gravel reduces salmonid egg survival. In studied Pacific Northwest streams, when fine sediment exceeded 13% of redd composition, no steelhead or coho salmon eggs survived. Chinook salmon are the most susceptible to sediment loading, followed by coho, steelhead, and cutthroat trout (McHenry et al. 1994; Lotspeich & Everest 1983; EPA 2005). — U.S. Environmental Protection Agency, UNKN (https://www.epa.gov/sites/default/files/2015-10/documents/ch3c.pdf); U.S. Environmental Protection Agency, 2005 (https://www.epa.gov/sites/default/files/2015-10/documents/ch3c.pdf) Rescinding the Roadless Rule would open the South Mills River, Pisgah National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Roadlesso wilderness is a rare thing in this world and we can't get it back once it's gone. The Roadless Rule stays on the books. That's my position. Hopefully,

I strongly oppose rescinding the 2001 Roadless Area Conservation Rule. The remaining intact forests and headwaters on our national forests are natural water infrastructure. Removing their protections would put watershed resilience and downstream water security at risk. I live near the confluence of the North, Middle, and South Forks of the Nooksack River in Whatcom County, Washington. My work centers on watershed restoration and ecological forestry. I have spent approximately thirty years climbing and twenty years mountaineering. The Mt. Baker–Snoqualmie National Forest is a place I love and know intimately through years of returning to its mountains, forests, and headwaters. On visits to Deming Glacier, at the headwaters of the Middle Fork Nooksack, I have watched a substantial part of its lower portion disappear. Its meaning is immediate: the sources of stored water sustaining our watershed are changing. We need to protect the watershed functions we can protect. Forest management is water management. Water security depends on when water arrives, how quickly it moves, its temperature and quality, and how much remains during the driest months. More runoff during a winter storm does not resolve a shortage of cold water in August. Older, native, structurally complex forests have a living architecture that develops over centuries: layered canopies, diverse vegetation, large wood, roots, and intact soils. A plantation does not immediately replace those functions. Forest condition influences interception, evapotranspiration, soil water storage, snow processes, and the pathways connecting hillslopes to streams. Treating all tree cover as hydrologically interchangeable obscures these differences. Long-term research makes the summer-flow concern especially clear. Perry and Jones (2017, Ecohydrology) analyzed sixty-year records from eight paired-basin experiments in Oregon. Average July–September streamflow in basins with 34–43-year-old Douglas-fir plantations was approximately 50 percent lower than in reference basins with 150–500-year-old forests. That number should not be applied mechanically to every Washington watershed. It does demonstrate that converting older forests to plantations can produce substantial summer-flow deficits decades after cutting. The Forest Service must evaluate these long-term effects, including regrowth and repeated harvest, rather than emphasize initial runoff increases. The 2022 South Fork Nooksack forest-management and August-streamflow modeling report prepared for the Nooksack Indian Tribe also deserves consideration. Roads introduce another set of risks. Road surfaces, cut slopes, ditches, and culverts can intercept and reroute water, connect runoff to channels, and deliver sediment. Their hydrologic footprint extends beyond the driving surface. Closing a road to traffic is different from restoring its hydrologic function. Forest effects on flood peaks vary with storm magnitude, basin characteristics, and management. Intact forests cannot prevent every flood. Nevertheless, avoidable changes to runoff pathways, erosion, and sediment delivery deserve serious assessment. Uncertainty about a precise downstream effect is not a reason to ignore the mechanism or the cumulative pressure. These headwaters are connected to watersheds already affected by roads, development, and timber management across public and private lands. Private industrial timberlands must be included in the cumulative assessment. Remaining intact federal lands should strengthen watershed resilience. Opening them to additional disturbance risks undermining investments in salmon recovery and watershed restoration downstream. I ask the Forest Service to retain the Roadless Rule and evaluate an alternative that strengthens intact-watershed protection while prioritizing maintenance and restoration of existing roads. The analysis must address peak flows, summer low flows, baseflows, evapotranspiration, seasonal water yield, snow dynamics, sediment, temperature, and relevant groundwater pathways over decades. Wildfire concerns require evidence specific to forest type, treatment, and location. The agency must explain why existing exceptions are insufficient and compare claimed safety benefits with road-related ignition risks and watershed costs. Broad claims about management flexibility do not justify removing a national conservation safeguard. Our full balance sheet must include the ecological capital these forests already provide. Protecting their living architecture is an investment in public infrastructure and water security. I love these mountains, and I live downstream of them. Please protect the intact headwaters that sustain the rivers, salmon, and communities below.

Keep the Roadless Rule. Select the "No Action Alternative" to keep the existing rule. I'm a wildlife biologist, retired. I know first hand the value of roadless lands to wildlife. The Elk, Logging, Roads studies at the University of Montana in the 1970s firmly established the importance of roadless areas to elk security. Research since then has reinforced that fact. The South Fork Grizzly Bear study of the 1980s and 1990s documented the critical importance of roadless areas to grizzly bears. The value of roadless lands to other wildlife species and communities is also well established. Montanans appreciate wildlife and place a high value on wild lands that support wildlife. Why would you jeopardize all that for this ill-conceived and reckless action? This proposal suggests a not-so-hidden agenda to privatize our valued public lands and resources. It will socialize the risks and costs (we pay) while privatizing the benefits to the few rich and powerful. We are not fooled by this action. This proposal is intended to promote roadbuilding and industrial development that will not only impact wildlife habitat and population survival, but makes no economic sense. It will degrade important drinking water sources for millions of Americans, spread invasive species and noxious weeds, increase the risk of wildfires (as documented in the draft EIS), and have permanent negative impacts on Tribal sacred lands and treaty-reserved resources. The Forest Service already has a multi-billion dollar deferred road maintenance backlog. Don't add to the problem This proposal will rob from me and millions of other Americans the opportunity to access quiet recreation sites that contribute to our physical and mental health. Do the right thing for all of us who depend on these areas. Withdraw your proposal, and help keep America great.

Dear Director, Ecosystem Management Coordination, 201 14th Street 1108, Washington, D.C. 20250-1124 I have lived and explored Wyoming’s most amazing forest service roadless areas for more than 45 years. I treasure the fact that these areas have been protected from development. They are important for protecting wildlife, air and water quality and maintaining the quiet and outstanding vistas of the mountains. With nearly 50% of all Forest Service lands open to development, Americans need to know that these special areas not roaded and not developed will be set aside for future generations. Roadless Areas In the Bighorn National Forest where I live, horse and back pack, camp, fish and paint must continue to be protected: Tensleep Canyon, Leigh Creek, Horse Creek Mesa, Little Bighorn River Canyon, Walker Prairie, Rock Creek of the Bighorns, Devils Canyon and more are spectacular landscapes. The Bridger Teton National Forest is an important wildlife, water and wild area: Roadless Areas that must be protected include: Commissary Ridge, Grayback Ridge, South Wyoming Range, Gros Ventre Mountains, including Spread Creek, Mosquito Lake, and the West Slope of the amazing Wind River Mountains. In the Medicine Bow NF Roadless Areas deserving continued protection include: French Creek, Rock Creek, Solomon Creek, Pennock Mountain, Sheep Mountain, Bear Mountain, Laramie Peak (where I camped and watched the solar eclipse!), Labonte Canyon, Buffalo Peak. The Shoshone National Forest which surrounds Yellowstone National Park and provides critical habitat for grizzly and black bears, elk, pronghorn, wolves, mountain lions, bobcats, lynx, and more has such important roadless areas justifying further protection include: The Beartooth Plateau, Franc’s Peak, Trout Creek, Windy Mountain, Wapiti Valley, South Fork,Telephone Draw, The Dunoir, Togwotee Pass, the Reef, Wood River. The Thunder Basin National Grassland also has important remnant roadless areas which need to maintain their protections: Duck Creek, Cow Creek and the Red Hills. I support the “No Action” alternative for the more than three million acres right here in Wyoming. The Roadless Rule needs to be in place not just for my beloved Wyoming areas but for all of America’s National Forests. Sincerely, Liz Howell 345 W. Whitney St Sheridan. Wyoming 82801 lizhowell345@gmail.com

I urge the Forest Service to retain Roadless Rule protections in the Flathead watershed and to support the proposed provision allowing Class 1 e-bikes on National Forest System trails where conventional bicycle use is already permitted. One of the keys to successfully protecting the Flathead River system is the network of overlapping protections that safeguard its rivers, watersheds, lands, wildlife, and natural resources. These include federal laws and regulations governing the National Forest System and National Park Service, the Wilderness Act, the Endangered Species Act, and, most importantly, the Wild and Scenic Rivers Act and the Flathead’s Wild and Scenic River designations. The Roadless Rule is another important part of that protective network. In the Flathead watershed, Inventoried Roadless Areas protect important lands in the Trail Creek, Whale Creek, Logging Creek, and Big Creek drainages of the North Fork; the Morrison Creek, Granite Creek, Bear Creek, and other tributary drainages along the Middle Fork; and the Spotted Bear River, Bunker Creek, Twin Creek, and other drainages of the South Fork. These protections also extend to numerous tributaries flowing into Hungry Horse Reservoir. These roadless lands are not separate from the Flathead River system—they are an integral part of it. The condition of the surrounding watersheds directly affects the river’s water quality, sediment levels, fisheries, wildlife habitat, scenic character, and recreational values. Maintaining intact, largely undeveloped watersheds provides an important measure of protection for the river itself. I recognize that rescinding the Roadless Rule would not automatically authorize a particular road, timber sale, or development project. However, the Forest Service acknowledges that rescission could increase opportunities for road construction, vegetation management, fuels treatments, and other activities in areas where existing forest plans allow them. The Roadless Rule therefore serves as an important national safeguard against incremental development of some of the most intact watersheds associated with the Flathead River. For a river system as nationally significant as the Flathead, I believe it is prudent to maintain that additional layer of protection. Once roads and associated development penetrate intact watersheds, their effects can extend well beyond the immediate footprint of the road. Protecting the surrounding lands is therefore an important part of protecting the river. At the same time, I support sensible modernization of recreational access where it does not compromise the fundamental roadless character of these lands. In particular, I support the Forest Service’s separate proposal to exempt Class 1 electric bicycles from motor vehicle designation requirements when they are used on National Forest System trails where conventional bicycle use is already permitted. Class 1 e-bikes provide pedal assistance only while the rider is pedaling and are limited to 20 mph. Allowing them on trails already open to bicycles would provide additional recreational opportunities without requiring roads or other infrastructure, while retaining the ability of Forest Service officials to impose seasonal, land-management, and site\-specific restrictions. I believe these positions are compatible. We can preserve the essential roadless character and watershed protections of the Flathead while allowing carefully defined, low-impact recreational uses that reflect modern technology. For these reasons, I support retaining the Roadless Rule protections applicable to the Flathead watershed and supporting the proposed Class 1 e-bike provision for National Forest trails where bicycle use is already permitted. Thank you for considering my comments. Bob Jordan

October 5, 2026 Director, Ecosystem Management Coordination U.S. Department of Agriculture, Forest Service 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 RE: Comments on Proposed Rescission of the 2001 Roadless Area Conservation Rule and Draft Environmental Impact Statement, Docket No. FS-2025-0001; RIN 0596-AD66 Dear Director: The City of Harrisonburg respectfully submits these comments in opposition to the U.S. Department of Agriculture's proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). The City requests that the Forest Service select the No Action alternative and retain the Roadless Rule. The Rule provides nationally consistent safeguards that generally prohibit road construction, road reconstruction, and timber harvesting in inventoried roadless areas, subject to limited exceptions. Those safeguards are essential to protecting the water resources, recreation opportunities, and community benefits on which Harrisonburg relies. Harrisonburg has a longstanding and direct interest in management of the George Washington National Forest (GWNF). In 2008, the Harrisonburg City Council adopted a resolution calling on the Forest Service to provide comprehensive management and protection of drinking-water resources within the GWNF. In 2010, the City reiterated that maintaining protection of its water resources was the most significant issue associated with the Forest Plan. Those concerns remain unchanged. The GWNF is integral to the protection of Harrisonburg's drinking-water supply. The City provides drinking water to more than 60,000 people and relies on surface-water intakes on the Dry River and North River; as well as constructing a new supply from the South Fork of the Shenandoah River. These supplies are fed by headwaters that flow from nearby roadless areas. The Skidmore Fork, Gum Run, Oak Knob, Little River, Ramseys Draft Addition, Crawford Mountain, and Elliott Knob Roadless Areas all help protect watersheds important to the City. The City's Dry River source illustrates the public value of maintaining these protections. The City's Comprehensive Plan identifies the source as minimally affected by development, of sufficiently high quality to require relatively little treatment, and positioned to provide gravity flow to the Water Treatment Facility. Protecting this type of high-quality source water avoids or reduces future treatment and energy costs borne by utility customers. Protecting drinking-water watersheds also supports long-term water-supply resilience for Harrisonburg and other Shenandoah Valley communities. Road construction and associated ground disturbance can increase erosion and sedimentation, adversely affecting streams and downstream water supplies. Rescinding the Roadless Rule would eliminate an important preventive safeguard. Local forest planning and site-specific environmental review should reinforce, not replace, the Rule's clear, nationally applicable protections for inventoried roadless areas. Roadless areas also provide significant recreation, habitat, and economic benefits to Harrisonburg and the surrounding region. They support hiking, mountain biking, hunting, angling, and backcountry experiences that draw visitors to the Shenandoah Valley and sustain local businesses. Their intact forests and cold, clean streams support wildlife, including native brook trout, while helping preserve the natural character that makes this region a destination for residents and visitors alike. The City recognizes the Forest Service's need to address wildfire, forest health, and other management needs. The existing Roadless Rule already includes exceptions and does not preclude all management activity. Rescission is neither necessary nor appropriate to preserve the ability to address site-specific risks. Any forest-management approach affecting roadless areas must continue to protect source-water quality and quantity and provide meaningful early coordination with the local governments that depend on those watersheds. For these reasons, the City of Harrisonburg strongly opposes rescission of the 2001 Roadless Area Conservation Rule and urges the Forest Service to retain the Rule. Maintaining these safeguards is a prudent and cost-effective means of protecting Harrisonburg's drinking-water supplies, supporting the regional recreation economy, and preserving important natural resources for current and future generations. Sincerely, Alexander Banks VI City Manager City of Harrisonburg

As a PCT'19 alumni and wildands advocate, I oppose the repeal of the Roadless Area Conservation Rule. There are 63 roadless areas along 288 miles of the PCT in California, Oregon and Washington. These miles represent roughly 11% of the trail. Roadless areas provide clean drinking water to 60 million Americans. This also provides connected wildlife corridors and undisturbed natural connected ecosytems. These undeveloped lands are critical to our nation’s ecological health.  These areas store 20% of all carbon in U.S. national forests. Roadless areas offer abundant outdoor recreation opportunities such as hiking hunting, fishing, camping and other activities. Every year, millions of people take advantage of the free (or extremely affordable) access to these public lands. The outdoor recreation economy generates $730 billion annually, far more than timber sales. Roadless areas are crucial habitat for 1,600+ threatened species. We already have 370,000 miles of forest roads with a multi-billion dollar maintenance backlog. Studies show wildfire ignitions are 4x more likely near roads than in roadless areas Please keep these roadless areas roadless! Deep Creek IRA—San Bernardino National Forest: On the north slope of the San Bernardino Mountains about 60 miles east of Los Angeles. Starting at 6,200 feet above sea level, the stream through the IRA drops about 3,000 ft through dramatic canyons in its 22-mile course before flowing into the East Fork of the Mojave River. It includes deep pools and hot springs and is a popular spot for day hikers. South Sierra IRA—Inyo National Forest: On the PCT and near the South Fork of the Kern River. San Joaquin IRA—Inyo National Forest: Red’s Meadow is a beloved respite along the PCT and a starting point for horse packers at the Agnew Meadows Pack Station. Dardanelles IRA—Lake Tahoe Basin Management Unit: Nearly the entire PCT from Carson Pass to Echo Summit is in this roadless area. Granite Chief IRA—Lake Tahoe Basin Management Unit: Heading north from Barker Pass, the PCT, and the contiguous Tahoe Rim Trail climb to dramatic ridgelines, yielding dreamlike views of Lake Tahoe amidst red fir and hemlock forests. Further north, the trail enters Granite Chief Wilderness and intersects the Western States Trail. Areas between Granite Chief Wilderness and Donner Pass are within this IRA, jeopardizing views enjoyed by thru-hikers, day hikers, and even skiers who use Olympic Valley, Lake Tahoe’s largest ski park. Mount Eddy IRA—Shasta-Trinity National Forest: Just across the valley from Mount Shasta, Mount Eddy is the tallest peak along the Trinity Divide, and the tallest peak in CA west of I-5. This subrange of the Klamath Mountains features a unique landscape of towering granite spires, lush evergreen forests, and alpine lakes deep in glacier-carved cirques. The area is under the jurisdiction of the U.S. Forest Service and was established as a Research Natural Area (RNA) to study its ecological significance, serving as the headwaters for the North Fork Sacramento River. Grider IRA—Klamath National Forest: This is a popular area for campers and day hikers along the creek, which feeds the Klamath River. Severely burned in the 2014 Happy Camp Complex, the regrowing brush gives way to large stands of surviving trees, and the sound of rushing water is a constant along the trail. The area has already been the subject of a legal fight over logging. Norse Peak IRA—Okanogan-Wenatchee National Forest: Next to Mount Ranier National Park, Sheep Lake is a picturesque alpine lake and a welcome destination for families for swimming, backpacking and camping. The hike to the lake is a gentle, 1.8-mile climb past summer wildflowers and red huckleberry plants in the fall, with great views of the Rainier fork of the American River, Mount Rainier, and Naches Peak. Liberty Bell IRA—Okanogan-Wenatchee National Forest: Some 30 miles of the PCT from Rainy Pass to Harts Pass, including the popular day hike to Cutthroat Pass, are within this large IRA. Situated in the heart of the North Cascades, this area is home to the mighty Methow River, many alpine passes, and some of the highest elevation stretches of the PCT in Washington.

I am writing as a Private land owner with land adjoining the South Fork Trinity Roadless area to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RR). I urge the Forest Service (FS) to retain the current RR under Alt. 1 & reject the proposed nationwide rescission under Alt. 2 & any alternative that substantially weakens protections. The DEIS stated purpose of the proposed rescission emphasizes greater local decision-making authority in forest planning processes. Yet, the original RR was established in part due to the failure of local forest planning process to maintain ecological, cultural, & public values of roadless areas to an adequate level. Returning these decisions to wholly local planning processes should not be treated as a substitute for consistent nationwide protection measurements. As a Land owner, I am concerned about the claim that removing the RR is necessary to reduce wildfire risk & that putting these forests under local control would have little adverse impact on the ability to protect their values as undeveloped wildlands. The DEIS recognizes that increased road construction can provide additional opportunities for wildfire response & fuels management, but it can also increase opportunities for unplanned human-caused ignitions. 96.2% of fires start within 800m of a road (Pacific Biodiv. Inst.). More roads=more fires. Wildfire risk reduction should not be used as a blanket justification for expanding roads & resource extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities & firefighters, rather than broadly removing protections from remote landscapes. I urge the FS to explain how proposed road construction or vegetation management would demonstrably improve community protection, firefighter safety, ecological resilience, and Recreation, & to fully account for the increased ignition risks & long-term maintenance burdens associated with new roads. The agency should disclose & analyze the potential for new roads to increase suppression complexity, vehicle hazards, traffic congestion, emergency evacuation challenges, invasive vegetation & future human-caused wildfire ignitions. Claims that road construction will improve firefighter safety must be supported by an analysis of the specific operational conditions under which new roads may provide a potential safety benefit—but also create new safety risks & hazards during suppression operations. Roadless areas provide some of the largest remaining undeveloped landscapes in the National Forest System (NFS). Removing nationwide protections could increase opportunities for road construction & logging, mining & drilling, with impacts degrading wildlife habitat, connectivity, water, soils, biodiversity, recreation & other ecological values. The RR was initially implemented to protect the ecological values of these forests as a connected & biodiverse landscape that local control could not account for. The DEIS acknowledges that more road construction & timber harvest are reasonably foreseeable if the RR is rescinded or revised. I am particularly concerned about wildlife habitat and connectivity, clean water, soil erosion & invasive species. The FS should not rely solely on future, site-specific project reviews to protect these values. Once protections are removed, individual decisions may fail to account for the cumulative loss & fragmentation of roadless landscapes across the NFS. The DEIS recognizes that additional road construction & timber harvesting could have long-term negative effects on Tribal rights & interests, including impacts to treaty-reserved resources, sacred sites, ancestral trails & culturally significant areas. I urge the FS to ensure meaningful Tribal collaboration & to fully incorporate Tribal knowledge & concerns before any decision is made to remove protections. Regarding Indigenous sovereignty, I am particularly concerned about sacred sites, treaty-reserved resources, traditional gathering areas, cultural forestscapes, and increased unauthorized access. New roads can also increase physical access to areas that have previously remained relatively protected from unauthorized entry, human-caused disturbance, & resource extraction. These consequences should be considered alongside direct impacts to culturally significant places & treaty-reserved resources. Future consultation on individual projects is not an adequate substitute for considering these impacts before a nationwide protection is removed. I am concerned that my adjoining private land will be impacted by roads and road use! For these reasons, I urge the FS to retain the RR under Alt. 1 & reject the proposed rescission, ensuring that wildfire policy is grounded in operational reality, ecological integrity, Tribal knowledge & rights, & the long-term safety of firefighters & communities.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The country I move through on foot, on a bike, and on water is the reason I am filing this comment. As an avid trail-runner, hiker, and camper across the western states, I rely on these landscapes for recreation, adventure, exercise, and solitude. In this day and age we humans need the ability more than ever to find solitude in nature for peace and mental reset. The 2001 Roadless Area Conservation Rule is a structural guarantee of that opportunity, and its rescission would eliminate something that cannot be rebuilt once it is gone. I travel long and far to discover remote mountain bike trails, particularly in the Uinta-Wasatch-Cache and Bridger-Teton areas of Utah and Wyoming. I also ride in Montana's Bitterroot, Flathead, Helena-Lewis and Clark, and Lolo national forests. These landscapes do not deserve to become more fragmented by new roads, logging, and mining. The Bridger-Teton alone holds 19 inventoried roadless areas totaling 1,417,499 acres, and it functions as the western wall of the Greater Yellowstone Ecosystem, the largest intact temperate ecosystem in the world. The elk herds that winter in the National Elk Refuge depend on summer range in those roadless mountains, and the agency's own record documents that elk survival rates rose during a road closure and fell again when the gates were removed. Rescission places that relationship directly at risk, and I ask the agency to address what road expansion in the Bridger-Teton and the Bitterroot's 405,883 roadless acres will mean specifically for elk populations that select habitat away from roads. The Bitterroot holds the Selway-Bitterroot Wilderness and its roadless buffer, described as the largest wild complex in the lower 48, where grizzly bears, wolves, wolverines, and mountain goats roam. These animals do not need yet more human degradation of their natural spaces. For whitewater paddling I am concerned about the South Fork Salmon River and its headwaters in Idaho, the Grande Ronde River in Oregon and Washington, and the Upper Chattooga River in Georgia and South Carolina, which runs through the Big Mountain and Ellicott Rock Roadless Areas and still feels remarkably wild. Anyone who has spent time near moving water understands that building roads and the associated sediment runoff anywhere near waterways is one of the worst enemies of water habitat. The agency's own analysis states that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, reducing egg survival, rearing densities, and growth of salmon. The affected area includes Essential Fish Habitat managed by NMFS. The agency should explain publicly how it reconciles those documented sediment and temperature effects with a proposal that would remove the principal regulatory barrier to new road construction across these watersheds. The wildfire justification offered for rescission contradicts what the agency has already put in its own record. "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." Having lived through wildfires in Colorado, I understand that rescinding the Roadless Rule could increase wildfire risk in all States by opening previously protected forests to more roads and human activity, potentially creating additional human-caused ignitions without guaranteeing that those roads will significantly improve wildfire suppression. The agency must explain why this proposal departs from its own prior findings on fire occurrence, and 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 economics do not hold together 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." This agency is nearly 6.9 billion dollars behind on maintaining roads it already has, against a budget of about 75 million a year. Building new roads into country that has none cannot be justified under those conditions. Explain how expanding a road system carrying a $6.9 billion maintenance backlog serves the public interest. These lands belong to all of us. Hiking, hunting, fishing, backcountry recreation, and the opportunity for solitude are legitimate public-land uses, and the Roadless Rule is what keeps them available. Keep our clean water clean, keep roadless areas roadless, and withdraw this proposal. Sincerely, Concerned Citizen Longmont, Colorado

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Creatures that need protection: bison, wolves, elk, moose, hummingbirds, and even spiders are all part of our natural world and deserve a clean, safe home. I have ridden my bicycle on trails in nearly every state in the country. Our natural places are one of the greatest things we have going for us. They need protecting. Rescinding the 2001 Roadless Area Conservation Rule would threaten both, and I oppose it. The roadless areas I am most concerned about are the South Fork area of 16,786 acres and the Underwood area of 3,046 acres in the Shasta-Trinity National Forest, and the Cow Creek area of 1,271 acres in the Six Rivers National Forest, all in California. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. These are not abstractions. On wildlife: the DEIS itself documents that habitat fragmentation reduces biodiversity by 13 to 75 percent, that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter. The agency's own words acknowledge that wide-ranging mammals like the grizzly bear "have suffered habitat loss and the extirpation or fragmentation of their populations." The elk I hope to see in places like South Fork depend on exactly the kind of habitat this rule protects. The agency's own sources found that elk survival rates rose during a road closure and fell again when the gates were removed, and that ideal summer elk habitat is unroaded land with cover and forage. For moose, the DEIS notes they are drawn to road corridors for road salt, increasing human-moose conflict, and the agency's own Tribal record credits the rule's protection with the recovery of deer and moose populations by preserving old-growth winter shelter. Building roads into these areas would directly harm the animals I care about. I ask the agency to explain specifically how it reconciles these findings with the proposal to lift protections. The agency's small-business analysis cannot be reconciled with its own cost figures. 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. The supporting analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, not the outfitters and guides actually holding permits in the affected areas. People who lead bicycle tours and wildlife trips through these forests are exactly the small businesses that would feel this loss first. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. The agency invited reliance interests and then declined to weigh 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. My own riding and my own wildlife watching in these forests are reliance interests. An agency changing course must account for what its prior policy encouraged people to count on. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. The agency's treatment of future plan amendments is internally contradictory. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). Inviting comment on a scenario the agency refuses to analyze is not a substitute for analysis. The foreseeable plan-amendment scenario, including expanded timber harvest area, must be analyzed as part of this action, not deferred to a later process that commenters cannot yet reach. Finally, the agency's own fire data undermines the proposal's safety rationale. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The trails I ride and the animals I look for do not survive catastrophic fire any better than they survive bulldozers. The agency has not quantified the expected increase in human-caused ignitions that would follow new road access, nor weighed that increase against any claimed reduction in wildfire hazard. That calculation belongs in this record before any final decision is made. Sincerely, Molly Martin Eureka, California

Subject: Public Comment opposing the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) To the U.S. Forest Service and the Department of Agriculture, I am writing to express my strong opposition to the proposal to rescind the 2001 Roadless Area Conservation Rule. As a resident of Park County, Montana, I urge the USDA to select Alternative 1 (No Action) to leave the 2001 Roadless Rule fully intact and protect our public lands. As someone who cares deeply about the future of Park County, Montana and surrounding public lands, I am concerned about how a rollback would impact the Custer Gallatin National Forest. Protecting these unfragmented landscapes is essential to me for the following reasons: Crucial Wildlife Migration Corridors: The roadless wild lands north of Yellowstone National Park serve as a primary corridor for wildlife moving through the Greater Yellowstone Ecosystem. Our wildlife species are already under threat from ongoing development in this region, maintaining these roadless areas is critical to allowing them to migrate safely through a connected landscape. Vital Habitat for Vulnerable and Iconic Species: Roadless areas hold low-elevation forests, wetlands, canyons and other undeveloped lands critical to overall ecological health. With no roads to divide them, these Roadless areas provide unbroken safety for many threatened and iconic species like grizzly bears, wolves and elk. Our local roadless areas and wildlife populations are deeply important. I regularly spend time in Roadless Areas in Park County and the Custer Gallatin National Forest. On a weekly basis I can be found hiking, skiing and observing wildlife in nearby drainages such as Suce Creek, South Fork of Deep Creek, George Lake, Mill Creek (including Wicked Creek, JoMaHa Creek) as well as the Jardine and Eagle Creek areas north of Gardiner Montana. Maintaining these sanctuaries as roadless is important to me and critical to the wildlife populations that reside and move through these areas. The Roadless Rule is a proven, forward-thinking policy that protects the fundamental resources of our local communities—our clean water, our economy, and our wildlife. Please abandon the proposal to rescind these protections and uphold Alternative 1 (No Action). Sincerely, Melissa Stringham Frady Livingston, Montana

Dear Secretary Rollins and Chief Schultz, As a kayaker and outdoor enthusiast, I am entering these comments to note that the proposed rescission of the 2001 Roadless Area Conservation Rule represents a fundamental reorientation of national forest management priorities — away from the long-horizon, public-value-centered framework the Rule embodies, and toward a project-by-project discretion that history suggests will not adequately protect roadless character. South Fork Mills River and the surrounding areas are places that I have visited with my family for generations. I hike and swim in this area frequently with my daughter and grandson. If this rule is rescinded I lose places that I go to for solace and to reconnect to nature and my family. Additionally, I am concerned about waterways that would be adversely affected as well as loss of precious habitat for bats, hellbenders, and many other species. Regarding the South Mills River in the Pisgah National Forest, North Carolina: Bat Habitat Connectivity Across Elevational Gradients — This area's elevation range—from 2,600 feet at Turkeypen Gap to 4,600 feet at Laurel Mountain—creates a continuous forest corridor essential for four federally endangered bat species: the Gray Bat, Northern Long-eared Bat, and Tricolored Bat (proposed endangered), which forage and roost across multiple elevations throughout the year. The unfragmented canopy and intact forest structure provide the interior habitat these species require; roads fragment this corridor into isolated patches, forcing bats to cross open areas where they are vulnerable to predation and collision. The roadless condition preserves the connectivity that allows these species to move between seasonal habitats without exposure. Roads fragment intact habitat through cut-and-fill earthwork, compact soils, reroute surface and subsurface water flow, and create impervious surfaces — each mechanism amplifying the effects of 9.3 - Agricultural & forestry effluents on Monarch. The DEIS must provide site-specific analysis of 9.3 - Agricultural & forestry effluents impacts to Monarch (Danaus plexippus) in the South Mills River IRA — not a programmatic discussion of roadless areas generally but a particularized assessment of this species in this place. "Road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations. The global extent of the problem is substantial and factors affecting the number of animals killed on highways include life-history traits and landscape features. Secondary effects include genetic isolation due to roads acting as barriers to migration. Long-term effects of roads on population dynamics are often severe and mitigation methods include volunteer rescues and under-road tunnels. Despite the development of methods that reduce road kill in specific locations, there is scant evidence that such measures will protect populations over the long term." — Conservation Biology (Wiley), 2013

I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user and advocate for our nation's public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. I frequently visit the South Fork Mills River near my home in Rutherford County, NC. Protecting these unfragmented landscapes is deeply personal to me because I enjoy bird-watching and hiking in this and other National Forest Areas. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Thank you for the opportunity to provide public comment. Sincerely, Bruce Whelchel Rutherford County, NC

As a avid fly angler who values our public lands, wild fisheries, and backcountry waters untouched by human activity, I strongly oppose the proposed rescission of the 2001 Roadless Rule (Docket FS-2025-0001 / RIN 0596-AD66). Inventoried Roadless Areas (IRAs) play an indispensable role in safeguarding the amazing wild steelhead and salmon watersheds of the West Coast. Specifically, the untracked forests flanking the Lower Klamath River, the Trinity River (including its critical South Fork), and the Rogue River act as a natural defense system for these legendary rivers. Fly fishing relies entirely on intact riparian ecosystems; by blocking commercial road building and industrial logging, these IRAs prevent catastrophic siltation, preserve old-growth canopies, and keep vital cold-water tributaries flowing clear. Removing these baseline protections would directly degrade the water quality and delicate insect life required for healthy salmonids, while forever altering the unique, remote walk-and-wade and drift-boat opportunities that make these canyons world-class fly fishing destinations. I urge the Forest Service to maintain the Roadless Rule in its entirety.

Dear Secretary Rollins, Thank you for the opportunity to comment on the proposed recission of the 2001 Roadless Area Conservation Rule. I am a resident of Missoula, Montana and a local whitewater paddler and river guide. I have many memories of paddling rivers within and fed by roadless watersheds like the North Fork Blackfoot River, Thompson River, Dearborn River, Big Hole River, and Rock Creek (Montana); Lochsa, lower Selway, St. Joe, South Fork Snake (Idaho); Chetco and North Fork Smith (Oregon). Rolling back the Roadless Rule through either Alternative 2 or 3 will threaten drinking water supplies, big game and fish habitat, and hunting, angling, paddling, and other outdoor recreation opportunities; increase wildfire risk; and burden the Forest Service with more roads it can’t afford to maintain. On one hand, this administration has been clear in that its goal is to increase logging, mining, and energy development across public lands, including within roadless areas. On the other hand, this administration claims that rolling back the Roadless Rule would return decision-making to local officials—”local” officials who remain beholden to the same bosses in DC who are cutting their budgets, firing their staffs, and aggressively mandating expanded logging, mining, and energy development. This administration also falsely claims that repeal is needed for reducing wildfire risk. In fact, new roads have been shown to increase human-triggered wildfires, and the current Roadless Rule already allows exceptions for wildfire treatments. Overall, the agency’s rationale for rolling back the Roadless Rule is unsubstantial, overwhelmingly lacks public support, and conflicts with its own findings in the Draft Environmental Impact Statement. I strongly recommend that the agency adopt Alternative 1, the no-action alternative, which will keep the Roadless Rule in place and retain the benefits it gives me and others including: 93% of elk summer range in Montana is found within roadless areas. Roadless areas also provide secure habitat during hunting season that keeps big game on public land where they are accessible to hunters in top hunting areas like the Elkhorns, Snowcrest, and Rocky Mountain Front. What’s more, 79% of roadless areas in Montana are home to native trout, including bull trout, Westslope cutthroat trout, and Yellowstone cutthroat trout. Studies have demonstrated that roads can lower trout populations by causing water quality degradation from increased sediment and pollutants, as well as altered stream channels, fragmented habitat, and migration barriers. Montana’s $3.4 billion outdoor recreation industry supports tens of thousands of jobs – from outfitters and guides to gear shops, lodging, and local restaurants. This industry thrives because of the intact, roadless landscapes that draw visitors from across the country and provide Montanans with unparalleled access to the outdoors. As of 2023, 78% of human-caused fires on national forests nationwide start within ½ mile of a road. 85% of all wildfires are human-caused. Wildfires are four times more likely to start near roads. The Roadless Rule already allows the Forest Service to treat roadless areas to reduce wildfire risks. Since the 2001 Roadless Rule went into effect, there have been 188,393 acres of hazardous fuels treatments conducted in roadless areas within Montana. This represents 20% of all hazardous fuels treatments during this timeframe. The Roadless Rule Already Allows for: 32% of motorized trails on national forest land in Montana are located within roadless areas, totaling 878 miles of trails open to off-highway vehicles. The Roadless Rule simply prevents new roads 2.2 million acres of roadless areas in Montana are within grazing allotments. This represents approximately 1/3 of all allotments on national forest lands in the state. The 2001 Roadless Rule recognizes valid existing rights for oil and gas development and does not prohibit new leasing. However, over 90% of roadless areas in Montana are rated as having low or very low potential for oil and gas production There are 370,000 miles of road on our national forests, enough to circle the Earth nearly 15 times. The Forest Service is burdened by a $8.6 billion deferred maintenance backlog, 58% of which is due to dilapidated roads. We need to take care of the roads we already have, not add more roads that the Forest Service doesn’t have the resources or personnel to maintain. Thank you again for the opportunity to comment on this important decision that affects me and my livelihood. I strongly recommend that the agency adopt Alternative 1, the no-action alternative, and forego proceeding with rescinding the Roadless Rule.