Every public comment on the proposed rescission of the Roadless Rule, sorted by what it talks about. Pick a topic, then narrow by position, by how hard the comment is for the agency to set aside, or by how substantive it is. Each comment is shown in full, as filed. How comments are classified and scored is explained in the Comment Analysis.
Opposes rescissionA1 strongSubstance 15/24Owed an answerOct 7, 2026FS-2025-0001-605608
PLACESTANDDOCGAPEVIDASKALTLAW
The Wasatch and Uinta mountains are where I hike and camp, and protecting those places is exactly why I am filing this comment. Mill Creek Canyon in the Uinta National Forest, White Pine and Twin Peaks in the Wasatch-Cache National Forest, these are the wild, unroaded landscapes I want my children and their children to be able to experience. The proposal before the agency would put all of that at risk, and the agency's own record makes clear it should not proceed.
Utah holds 222 inventoried roadless areas totaling 4,013,529 acres. These are not abstract acres. They are the backcountry I depend on, the places that are still genuinely wild precisely because roads have not reached them. More and more land is developed and destroyed, increasing fire risk, increasing watershed contamination, decreasing wildlife and plant populations. Rescinding the 2001 rule accelerates every one of those trends, and the agency's own analysis says so.
On wildfire, the agency's record states plainly: "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 nonetheless justifies rescission on fuels management grounds, which inverts what the agency's own findings show. I ask that the agency explain why the proposal departs from those prior findings 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.
Watersheds need to be kept pure. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. By the agency's own data, roads and their facilities contribute directly to contamination. The agency has acknowledged that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. How can that be justified when everyone needs access to clean water now more than ever? I want the agency to explain, specifically and on the record, how opening these watersheds to road construction serves the public interest in clean drinking water.
The economic case for rescission is just as weak. The agency's own 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 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, and the road system already carries a $6.9 billion maintenance backlog. The agency cannot establish a net benefit from this action by its own numbers. It must reconcile the proposal with that analysis and explain what economic rationale remains.
On the question of statutory authority, a court already answered it. The Tenth Circuit held: "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." The agency argues the 2001 rule exceeded its authority, but the Tenth Circuit found the 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 legal support, the basis for any position contrary to that holding.
Finally, the proposal itself acknowledges 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. The agency cannot ask the public to comment on consequences it has simultaneously placed outside the scope of its own analysis. The foreseeable plan-amendment scenario, including expanded timber harvest area, must be analyzed as part of this action, not deferred.
We do not want more roads, development, mining, or logging on our public lands. These lands should be left as wild spaces and backcountry. The agency held more than 600 public meetings and received 1.6 million comments before it put the 2001 rule in place. It has held none to undo it. That process debt alone warrants withdrawal of this proposal.
Sincerely,
Michelle Richardson
Sandy, Utah
As I look at pictures from the late 1800's, I am shocked that such destruction and devastation to our forests and rivers was ever allowed, and that it was perceived as progress and advancement. The Homestead Act of 1862 and subsequent land laws, like the Timber Culture Act of 1873, drove massive logging and deforestation across the American West. While the laws were intended to encourage settlement and agricultural development, they also created opportunities for lumber companies and speculators to exploit forested lands and cut down some of the most incredible and majestic forests on our planet. Giant Sequoias along with soft wood conifers like White pine, Douglas fir, Long leaf pine and Ponderosa pine were lost to this destruction and logging. These forests have never recovered from this horrific mass deforestation.
The Roadless rule was implemented in 2001 to protect 58.5 million acres of national forest land by prohibiting road construction, reconstruction, and timber harvesting. This rule is one of the most important and most valued in the history of the USDA. With more than 1.6 million public comments, this is a historic landmark for any rule in the U.S. Of all the comments received, 95% of the comments were in support of keeping roadless protections in place.
The Forest Service's FY26 budget slashes agency funding by more than 60%, and it zeroes out funding for Wildland Fire Management. This is basically stating that wildfire risk management is not their top priority and that they plan to give more power to individual states to decide on logging and land use. Wildfire management has been proven to be more effective in areas with less or no roads. One major reason for this is human access: roads have been linked with most forest fires because they enable human access and the majority of wildfires are human-caused. They also increase ladder fuel with the greater amount of dry, flammable vegetation near the road, and alter micro-climates to be hotter and windier, which also facilitates fire ignition and spread.
The importance of having pristine and untouched forests, rivers and streams is beyond what humans can imagine. The value of life itself lies in these places. There is a plethora of wildlife and organisms that depend on these forests, streams and clean rivers. We cannot keep appeasing logging, timber and electric companies to destroy our only habitat for profit and margins. We need to protect and value our ecosystem and stop corporations from destroying our forests and watersheds through ruthless exploitation and extraction of natural resources.
I strongly oppose rescinding the 2001 Roadless Rule. We need to keep strong protections in place and the agency needs to respect public opinion. The agency also needs to conduct a complete and thorough environmental analysis and secure that no watersheds will be damaged. The public wants to keep our public lands protected and untouched. Our future generations depend on your duty to protect our forests and rivers!
Important links attached to my comments:
Science on roads fragmenting the landscape: https://conbio.onlinelibrary.wiley.com/doi/epdf/10.1046/j.1523-1739.1996.10041098.x
Current rule in place: https://www.federalregister.gov/d/01-726/p-395
Forest Service FY26 budget: https://www.fs.usda.gov/sites/default/files/fs-fy26-congressional-budget-justification.pdf
As I look at pictures from the late 1800's, I am shocked that such destruction and devastation to our forests and rivers was ever allowed, and that it was perceived as progress and advancement. The Homestead Act of 1862 and subsequent land laws, like the Timber Culture Act of 1873, drove massive logging and deforestation across the American West. While the laws were intended to encourage settlement and agricultural development, they also created opportunities for lumber companies and speculators to exploit forested lands and cut down some of the most incredible and majestic forests on our planet. Giant Sequoias along with soft wood conifers like White pine, Douglas fir, Long leaf pine and Ponderosa pine were lost to this destruction and logging. These forests have never recovered from this horrific mass deforestation. The Roadless rule was implemented in 2001 to protect 58.5 million acres of national forest land by prohibiting road construction, reconstruction, and timber harvesting. This rule is one of the most important and most valued in the history of the USDA. With more than 1.6 million public comments, this is a historic landmark for any rule in the U.S. Of all the comments received, 95% of the comments were in support of keeping roadless protections in place. The Forest Service's FY26 budget slashes agency funding by more than 60%, and it zeroes out funding for Wildland Fire Management. This is basically stating that wildfire risk management is not their top priority and that they plan to give more power to individual states to decide on logging and land use. Wildfire management has been proven to be more effective in areas with less or no roads. One major reason for this is human access: roads have been linked with most forest fires because they enable human access and the majority of wildfires are human-caused. They also increase ladder fuel with the greater amount of dry, flammable vegetation near the road, and alter micro-climates to be hotter and windier, which also facilitates fire ignition and spread. The importance of having pristine and untouched forests, rivers and streams is beyond what humans can imagine. The value of life itself lies in these places. There is a plethora of wildlife and organisms that depend on these forests, streams and clean rivers. We cannot keep appeasing logging, timber and electric companies to destroy our only habitat for profit and margins. We need to protect and value our ecosystem and stop corporations from destroying our forests and watersheds through ruthless exploitation and extraction of natural resources. I strongly oppose rescinding the 2001 Roadless Rule. We need to keep strong protections in place and the agency needs to respect public opinion. The agency also needs to conduct a complete and thorough environmental analysis and secure that no watersheds will be damaged. The public wants to keep our public lands protected and untouched. Our future generations depend on your duty to protect our forests and rivers! Important links attached to my comments: Science on roads fragmenting the landscape: https://conbio.onlinelibrary.wiley.com/doi/epdf/10.1046/j.1523-1739.1996.10041098.x Current rule in place: https://www.federalregister.gov/d/01-726/p-395 Forest Service FY26 budget: https://www.fs.usda.gov/sites/default/files/fs-fy26-congressional-budget-justification.pdf
I would like to write a comment in support of the Roadless Rule. I view the Roadless Rule as a fantastic idea to protect, preserve and steward our national forests. The proposed rescinding of the rule is not about appropriate forest management, the Forest Service is already permitted to thin forests, do controlled burns, and develop roads for fire prevention as needed. Instead this is all about industrial logging, ripping the future of these forests away.
Old growth forests used to cover this continent until we chopped them all down. My hometown in the Upper Midwest began as a logging town, and the giant towering old white pines were cut down long before I was even born. As a result, I have never seen old growth white pine, trees take a long time to grow after all. I find reverence in the trees that I can experience, and I often wonder about what it would be like to see my hometown forests in all their old growth glory. For me, that will never be possible, my life will be too short, but for future generations it can be. If we can protect these forests, by choosing not to cut them down, we can safeguard these forests for future generations. Imagine how our children, or grandchildren, or great-grandchildren may one day find reverence in the old growth trees. For to choose to not cut down a forest is to choose to invest in the future, whereas cutting it down is like giving up. Imagine how grateful future generations would be if they knew that we chose to invest in their future because we believed they were worth it.
My name is Tulsi Shrivastava, and as a lifelong resident of the beautiful Appalachian Mountains, I strongly oppose rescinding the Roadless Rule. Having grown up, lived, and worked in the Allegheny Mountains, I care deeply about our wildlife and want future generations to experience the lush, green forests I have always called home. We must not allow the permanent destruction of our ecosystems for short-term commercial gain.
First, we must consider what we are leaving behind. Currently, 95% of Pennsylvania’s only national forest is already open to logging, mining, and oil drilling. If we remove protections, what will be left for future generations? The wildlife I have spent my life watching outside my window in the Alleghenies will simply cease to exist.
My family trips to the Shenandoah Mountains are some of my most cherished memories, and it is vital that we protect areas like the George Washington and Jefferson National Forests (GWJNF) from commercial logging and road construction. My husband and I dream of exploring the Los Padres National Forest in California, the Black River area in Arizona, and the vast wilderness of Alaska with our parents. I was raised to see the divine in nature, and the human-caused destruction of these environments pains me to my core. There is no justification for making wildlife and communities suffer to this extent.
Furthermore, intact forests provide essential environmental benefits. A UC Berkeley study on watersheds highlighted that natural, unsuppressed forest processes yield vital benefits: "increased stream flow, increased downstream water availability, [and] increased soil moisture, which improves habitat for the plants within the watershed." When natural events like wildfires do occur, a healthy, roadless forest canopy serves as the ultimate defense mechanism for our downstream water infrastructure.
Finally, decision-making authority should rest with local leaders and knowledgeable park rangers rather than a sweeping federal mandate. One blanket policy cannot accommodate the vast diversity of our great American lands. For example, Pennsylvania needs to preserve the old-growth in its white pine stands, while California requires targeted management for extreme wildfire risks. We must empower area-specific management to ensure the land gets the exact care it needs.
For these reasons, I fully support Alternative 1, the "No Action" alternative. Keep these roadless areas protected! As someone with friends across the political spectrum both Democrat and Republican, I know this is one issue our entire country can agree on.
What We Cannot Rebuild
In 1864, in the middle of the Civil War, Abraham Lincoln signed a bill granting Yosemite Valley and the Mariposa Grove to California, to be held "for public use, resort, and recreation" and kept "inalienable for all time." Eight years later, Grant signed the law creating Yellowstone, widely regarded as the world's first national park. A young nation protected land anyway, because some things, once spent, cannot be bought back.
The question is not whether mining and logging have mattered to America. They built much of what we live in. The question is whether the next acre of intact forest, roadless valley, or headwater should go on the ledger as one more resource to convert into revenue. History's answer, again and again, is that we regret it.
THE EMPTY FORESTS
In the nineteenth century, the white pine forests of Michigan, Wisconsin, and Minnesota were treated as inexhaustible. By about 1900 the pine logging of the Lake States was essentially finished, leaving some forty million acres of "cutover" land. The Peshtigo fire of 1871, fed in part by logging-altered landscapes, killed an estimated 1,200 to 2,500 people. Bison fell from an estimated 30 to 60 million to fewer than a thousand by the 1890s. The passenger pigeon, once numbered in the billions, was gone by 1914. Markets price what is in front of them well, and what can never be replaced badly.
THE CONSERVATIVES WHO CONSERVED
Theodore Roosevelt, a hunter, rancher, and Republican, protected roughly 230 million acres, including 150 national forests. He was no purist: "Conservation means development as much as it does protection." But in 1910 he set a standard: the nation should turn its natural resources over to the next generation "increased, and not impaired, in value." An open-pit mine with a perpetual water-treatment bill does not pass that test.
In 1913, Congress let San Francisco dam Hetch Hetchy Valley inside Yosemite. John Muir wrote: "As well dam for water-tanks the people's cathedrals and churches." He lost, and the valley lies under a reservoir.
WHAT THE LEDGER LEAVES OUT
A 2020 Government Accountability Office report found at least 140,000 abandoned hardrock mine features on federal land. Agencies spent roughly $2.9 billion on cleanup from fiscal 2008 through 2017 and estimate more than $10 billion for even a fraction of the rest. The public pays.
Colorado's Summitville gold mine is the textbook case: cyanide heap-leach mining, bankruptcy in 1992, then a Superfund cleanup estimated at $150 million or more, with water treatment needed indefinitely. In 2015, an EPA contractor at the Gold King Mine, idle for nearly a century, released about three million gallons of acidic waste into the Animas River. That is how long the bill takes to come due.
The General Mining Law of 1872 still governs hardrock mining on more than 270 million acres of public land, and companies pay no federal royalties on gold, silver, or copper, unlike oil, gas, and coal producers. In Alaska's Tongass National Forest, GAO found the timber program lost about $11.4 million a year from 2005 to 2014, before counting roads. We paid to cut trees that took centuries to grow.
THE ECONOMY IN THE STANDING FOREST
The Bureau of Economic Analysis reports outdoor recreation added $696.7 billion to the economy in 2024, 2.4 percent of GDP. Not all of that depends on public land, but it is no niche. Moab, Utah, once a mining town, now runs largely on tourism and recreation. Extractive towns boom and bust with the ore. None of this means ignoring families who depend on timber and mining wages. It means real transition support. The choice is between a managed transition and a cliff.
WHAT A COUNTRY IS FOR
A rival idea has always shadowed the one that treats land as inventory, running from Thoreau's "in Wildness is the preservation of the World" through Muir and Roosevelt to Aldo Leopold's land ethic. Native nations managed these lands long before Europeans arrived, and many hold the places now at risk to be sacred.
The Wilderness Act of 1964 defined wilderness as "an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain." It passed the Senate 73 to 12 and the House 373 to 1, by a country that could afford to cut and dig and chose not to. We are richer now.
WHERE THIS LEAVES US
We still need copper and lumber. The argument is about where and how.
- Draw the line at what cannot be replaced: roadless areas, old growth, headwaters.
- Make extraction pay its full cost: real royalties, reclamation bonding, an abandoned-mine fund.
- Fund transition for extraction communities.
- Make protection the default.
No one thanks the people who cut the last of the white pine. We thank the ones who set aside Yosemite and passed the Wilderness Act.
Wild places are the one inheritance we can give to the future only by refusing to spend it.
To the Department of Agriculture:
I grew up in Montana, and have worked for the Forest service in multiple capacities as well as numerous years of recreating in Wild areas across the United States.
For a person who has sought out roadless public land across different regions and in different seasons, I'd say the 2001 Rule is one of the clearest expressions of what the public land system is supposed to protect — and rescinding it would be a clear statement about what it isn't.
I grew up exploring places like the Crazy Mountains as well as others nearby.
My wife and I recently hiked to the blue lakes, where we were able to access an alpine area filled with unique wildflowers with no other person in sight.
Places accessible only by foot, that are protected from destruction by bulldozers and tires
Regarding the Crazy Mountain in the Gallatin National Forest, Montana:
Alpine and Subalpine Climate Refugia — The area's high-elevation ecosystems—Rocky Mountain Alpine Turf, Alpine Dwarf-Shrubland, and Whitebark Pine/Subalpine Fir Woodland—occupy the summits and ridges of peaks exceeding 10,700 feet and represent climate refugia where species can persist as lower-elevation habitats warm. Whitebark pine, a federally threatened species and IUCN-listed endangered species, depends on these high-elevation zones where it grows in association with subalpine fir; the species is already declining across the West due to white pine blister rust and mountain pine beetle. Road construction at high elevations would remove the canopy structure that whitebark pine requires and would increase human access that spreads invasive pathogens, directly undermining recovery prospects for this species in one of its remaining strongholds.
Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer.
“Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2)”
The Department's obligation under the APA is to provide reasoned explanation commensurate with the significance of the policy change; that obligation has not been met, and rescission should be denied.
All the best,
CommentID: RLC-20261006-E8VZJB
I am writing to express my strong opposition to the proposal to fully or partially rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule.
I am an ex-Forest Service employee, where I worked to educate the public on Leave No Trace principles and interpretation, and worked for several seasons both as a wilderness ranger and a wilderness trails crew member. I no longer work for the agency, but I am still an avid hiker, backpacker, and fisherman, and deeply value my public lands and the opportunities they give to spend time in the wilderness, encounter wildlife, and reconnect with myself through the natural world. National forests and inventoried roadless areas matter deeply to me because they provide that space for exploration and peace. As a resident of the Salt Lake Valley, I recreate in the Uinta-Wasatch-Cache National Forest, one of the most heavily used National Forests in the country. That forest protects Salt Lake's watershed, Current roadless sections include heavily used areas like Dog Lake and White Pine and vast tracts of the Unitas providing buffer zones around the High Uintas Wilderness, all of which protect our watershed and the ecosystem services our mountains provide. There are many, many places in the UWC with plenty of roads and access and development--as a Wasatch Front resident who has spent plenty of time stuck in the ski traffic jams up the canyons, I can definitely speak to that development.
Fully or partially rescinding the Roadless Rule would threaten unfragmented backcountry landscapes, wildlife habitats, and clean water sources. Roads fragment ecosystems in ways that cause long-term ecological harm, and dismantling these protections undermines the natural integrity of our public lands.
I urge the Forest Service to drop the proposed rescission and instead support Alternative 1 (the No Action alternative) to maintain full, permanent protections for all currently designated inventoried roadless areas.
Thank you for the opportunity to comment on this important issue.
Sincerely,
Clare Vergobbi
Salt Lake City, UT 84104
c.vergobbi@gmail.com
I’ve lived in Utah for 15 years and hope to retire here. As a regular trail runner, backcountry skier, and year-round user of local treasures including White Pine, Cardiff Fork, Days Fork, Silver Fork, Mineral Fork, Mt. Aire, Lambs Canyon, and upper Big Cottonwood Canyon, I strongly support keeping the Roadless Rule in place.
New roads would fragment quiet backcountry areas and wildlife habitat, increase erosion and sediment in important watersheds, and completely change the untouched character of these places. Rescinding the rule would also remove an important nationwide baseline for protecting roadless areas and shift decisions to individual forest plans and project reviews. These near-pristine, world-class landscapes are a huge part of why I value living here and showing my friends and family from out of state what makes Utah unique, and I hope they remain protected.
As someone who grew up near the Shenandoah Valley and the George Washington National Forest in Virginia, I strongly oppose rescinding the Roadless Rule. I care deeply about our wildlife, and my biggest concern is that my future kids won't be able to enjoy the lush, green forests I grew up around if they're opened up to commercial logging. We can't allow the permanent destruction of our ecosystems for short-term gain.
First, we really have to consider what we're leaving behind. Right now, 95% of Pennsylvania’s only national forest is already open to logging, mining, and oil drilling. This will make the area more unsafe for animals and humans alike. I’ve always loved the birds and wildlife in these woods. Honestly, I’m constantly looking online to figure out the exact species I just spotted—especially the Broad-winged Hawks and Red-shouldered Hawks that are so iconic to Virginia. If these habitats are destroyed, the incredible wildlife I've spent my life watching will simply disappear. My trips to the Virginia mountains are some of my best memories. I recently got married, and my wife and I have lots of plans to go hiking. I also absolutely love biking, and I want to make sure I can walk these same natural, untouched forests with my future kids one day.
It's so important that we protect the George Washington and Jefferson National Forests (GWJNF) from logging and road construction.
Beyond that, intact forests provide massive environmental benefits. When natural events like wildfires do happen, a healthy, roadless forest canopy acts as the ultimate defense mechanism for our downstream water infrastructure.
Finally, decisions about these lands should really be in the hands of local leaders and knowledgeable park rangers, rather than a sweeping federal mandate. One blanket policy just can't accommodate the massive diversity of our American lands. For example, Pennsylvania needs to preserve the old-growth in its white pine stands, while California requires targeted management for extreme wildfire risks. We need to empower area-specific management to make sure the land gets the exact care it needs.
Because of all this, I fully support Alternative 1, the "No Action" alternative. Please say no to rescinding the Roadless Rule and keep these areas protected.
Opposes rescissionA1 strongSubstance 15/24Owed an answerOct 5, 2026FS-2025-0001-559060
PLACESTANDDOCGAPEVIDASKALTLAW
Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
Ninety years of skiing, hiking, hunting, fishing, and teaching in National Forests give me standing to say this plainly: do not rescind the Roadless Area Conservation Rule. I am 101 years old. I was one of the first National Forest-certified ski instructors back in the late 1940s, and I have spent nearly my entire life in these mountains. The roadless rule is what makes living and working in them special. I am filing this comment in opposition to the rescission proposed under Docket FS-2025-0001.
The areas I know in the Wasatch-Cache and Uinta National Forests in Utah, including Mt. Olympus at 9,982 acres, Mt. Aire at 9,681 acres, Twin Peaks at 6,157 acres, Lone Peak Contiguous at 874 acres, White Pine at 1,942 acres, and White Baldy at 1,702 acres, are the kind of terrain the 2001 rule was written to protect. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres. These are not abstractions. They are the slopes and drainages where I have taught thousands of people to ski and where I have worked across generations. Opening them to road building would destroy the very quality that makes them worth going to.
The proposal argues that state-by-state approaches can substitute for a national rule. The agency's own record says otherwise. The USDA once stated its "dissatisfaction with the Roadless Rule" and criticized its "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. That position was put before the courts, and it did not survive. The Ninth Circuit found that local decision-making can incrementally erode nationally significant roadless values in ways a patchwork of state rules cannot prevent. I ask that the agency address its own prior finding on that point and explain specifically how this proposal avoids the deficiencies that court identified when the agency last attempted to replace the national rule with a state-by-state approach.
The proposal also argues that the 2001 rule exceeded the agency's statutory authority. That question was litigated. A federal appeals court, exercising jurisdiction pursuant to 28 U.S.C. Section 1291, ruled to "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." The Tenth Circuit held that the 2001 rule fell within authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must explain the basis for any contrary position it now holds.
On the question of administrative burden, the rule already contains its own safety valve. 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 proposal treats rescission as though no middle ground exists, but the rule's text shows otherwise. I ask that the agency identify, with specificity, which burdens are not already addressed by the existing exceptions, and that it quantify those burdens in the record rather than assert them.
The watersheds draining these Utah mountains supply drinking water to communities throughout the region. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas, according to DEIS Table 35. Road building accelerates erosion and sedimentation. Losing the protection these roadless areas provide to those intake watersheds is a direct public health consequence the proposal does not adequately weigh.
Finally, the regulatory flexibility certification does not hold up. 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. I have watched outfitters and guides build their livelihoods around these roadless slopes for decades. Averaging an annual expenditure loss of $9 million across every small firm in the sector nationally, rather than looking at the permit-holders actually operating in these areas, produces a meaningless number. The agency should withdraw the certification and conduct a genuine assessment of the small businesses whose operations depend on the specific roadless areas at risk.
I have spent nearly ninety years in these forests. The roadless rule protects what is left of what I first found there. Rescinding it would be a permanent loss.
Sincerely,
Junior Bounous
Provo, Utah
Opposes rescissionA2 moderateSubstance 14/24Owed an answerOct 5, 2026FS-2025-0001-559291
PLACESTANDDOCGAPEVIDASKALTLAW
Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
Twenty years of guiding river rafting and mountain biking trips, combined with my own backcountry skiing, have given me a close working relationship with the landscapes this proposal would put at risk. The inventoried roadless areas of the Wasatch-Cache and Uinta National Forests in Utah, including Mt. Olympus, Mt. Aire, Twin Peaks, Lone Peak Contiguous, White Pine, and White Baldy, are the kind of terrain I depend on professionally and personally. I am opposing rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001.
The wildfire rationale offered for this rescission conflicts directly with the agency's own 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." The areas I guide and ski in Utah, including the roadless terrain of the Wasatch-Cache, sit inside watersheds that are already under pressure. Opening them to roads in the name of fire management, when the agency's own DEIS Table 21 documents far higher fire density on roaded land, is a contradiction that demands a direct answer. I ask that the agency explain why this proposal departs from those prior findings and reconcile the rescission with the ignition data its own analysis produced.
The economic case for rescission is not established by the record. The agency itself acknowledges 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." Against that marginal extraction potential, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of only $5.2 to $11.4 million a year, offset by recreation losses of at least $6.1 million a year, with a net present value range spanning -$92 million to +$199 million. The Forest Service is already carrying a $6.9 billion road maintenance backlog. Expanding a road system that cannot be maintained, in order to capture a share of national production measured in fractions of a percent, does not constitute a reasoned economic justification. The agency must explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies that expansion.
As a guide and outfitter operating in these landscapes, I am directly named in the agency's own analysis. The proposed rule certifies no significant impact on small entities, yet the DEIS identifies outfitters, guides, and tour operators as affected parties, and the Cost Benefit Analysis records lost recreation benefit at a minimum of $6.1 million a year. The regulatory flexibility analysis reaches its no-impact conclusion by distributing an annual expenditure loss of $9 million across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas. That approach conceals localized harm behind a national average. The agency should withdraw the small-business certification and conduct an assessment focused on the specific entities operating under permits in the potentially affected roadless areas, not the industry as a whole.
Finally, 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. I have built a guiding career in part around the character and accessibility of roadless terrain in Utah. Utah alone holds 222 inventoried roadless areas totaling 4,013,529 acres, and across the Intermountain region 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The rule's protections have shaped decisions by guides, businesses, communities, and water users across that landscape for more than two decades. An agency changing course is required to identify and weigh the reliance interests its prior policy created. The agency must account for those interests, including the ones described in this comment, before any final action.
Sincerely,
Colin Gaylord
Salt Lake City, Utah
Good afternoon,
I do not support changes to the roadless rule which established prohibitions on road construction, road reconstruction, and timber harvesting with limited exceptions. Today, the 2001 Roadless Rule applies to nearly 45 million acres of National Forest System lands, including in Alaska. I have personally seen the benefits of the roadless rule during summers spent on public land in Northern Michigan where you can still find small stands of old growth White Pine, a keystone species for the region. Logging in the 1800s decimated their population and caused massive soil erosion issues through out the state, resulting in water pollution and a deeply impoverished populace once all the trees were gone. You can still see the impacts of that logging 100 years later. What was once pine trees has been replaced with fast growing hard woods like maple in much of the state. You can learn about the impacts on mass logging at Hartwick Pines State Park in Grayling, Michigan. What is left of our public forests still supports their surrounding economies by protecting the watershed, creating recreation areas, and supporting tourism and hunting. Please defend what is left of out Public Land. Keep the Roadless Rule in tact!
Opposes rescissionA1 strongSubstance 16/24Owed an answerSep 23, 2026FS-2025-0001-471816
PLACESTANDDOCGAPEVIDASKALTLAW
Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
I am writing about the Santa Fe National Forest in New Mexico, and I am asking this agency to reject the proposed rescission of the 2001 Roadless Area Conservation Rule.
Black Canyon and Little Tesuque have been part of my life for many years. I have hiked both, gone on birding expeditions through them, and joined small groups studying the trees. They are dear to my heart, and I know I am not the only one who feels this way.
The Santa Fe NF contains roadless areas I know well, among them Black Canyon at 1,922 acres, Little Tesuque at 815 acres, Pacheco Canyon at 1,012 acres, and the Juan de Gabaldon Grant at 8,023 acres in the high terrain of the Sangre de Cristo Mountains. Pacheco Canyon is a gorgeous multi-use trail I have hiked with friends and where I have seen others on bikes and horseback. The Juan de Gabaldon Grant sits close to Tesuque Pueblo, a community I have visited, and it lies within a watershed that must be protected from road development and what that would bring. Little Tesuque is a shaded, picturesque creek trail used by many locals in the Santa Fe area, popular for birding, easy hiking, biking, and running. Preserving it for that recreational use is essential to the well-being of people living here. Black Canyon provides locals and visitors a place to camp, hike, bird, and enjoy the ponderosas, aspens, and white pine.
The birding I do in these places is directly relevant to this proposal. The agency's own record states 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, with 31 percent of species avoiding the noise entirely." The DEIS cites Kroeger et al. 2022, McClure et al. 2013, and Ware et al. in support of these findings. Every road built into Black Canyon or Little Tesuque would fragment exactly the quiet, intact habitat that makes these areas worth photographing and worth visiting. I ask the agency to explain, specifically and in response to this comment, how those findings about bird abundance and species avoidance are reconciled with a proposal that opens these areas to road construction.
The agency's own findings on fire make the rescission harder, not easier, to defend. The DEIS 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." If fire risk is the justification, the data point the other direction. I ask that the agency reconcile this proposal with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain what analysis overrides its own prior findings.
Nichols Reservoir is a key municipal water storage area in the Santa Fe Municipal watershed. Water is critical in the high desert foothills of the Sangre de Cristo Mountains. The agency's record shows that across the Southwestern region, which includes New Mexico, 739 municipal water intakes sit in watersheds containing affected roadless areas. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres. Roads bring sedimentation, erosion, and contamination risk to source water. The agency must address the drinking water consequences for communities like Santa Fe before this rescission can move forward.
The economic case is also unsupported by the agency's own numbers. The DEIS states: "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." Against that marginal production gain, the agency's Cost Benefit Analysis projects recreation losses of at least $6.1 million a year and a net present value ranging widely, while the road maintenance backlog already stands at $6.9 billion. The agency must explain on the record how an action whose own analysis cannot establish a net benefit justifies further expanding that road system.
Finally, the rule as written already provides flexibility. It states that 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 has not identified which specific burdens fall outside those exceptions. It should do so, with specifics, not generalities.
These are real places with real communities, real water supplies, and real wildlife. The agency should withdraw the proposed rescission.
Sincerely,
Karen Weber
Santa Fe, New Mexico
Opposes rescissionA1 strongSubstance 16/24Owed an answerSep 21, 2026FS-2025-0001-453034
PLACESTANDDOCGAPEVIDASKALTLAW
Roadless areas in the Wasatch-Cache and Uinta national forests are not abstract policy to me. We have been hiking in the Mt. Olympus area for nearly 30 years. We hike Mt. Aire a couple times a year because it is a great connection between Parley's Canyon and Millcreek Canyon and has been relatively untouched so far by development. We live near both Twin Peaks and Lone Peak and spend about 25% of our outdoor time there. We photograph throughout the Wasatch Range and the Uintas, including White Pine, Twin Peaks, and Mt. Olympus. Our college-age son has recently taken up hiking again in a serious way and has been helping with inventory of rock glaciers in the White Pine area. This is not distant wilderness to us. It is where we spend our lives outdoors.
This area of the country may be the best for moose habitat. We have been all over the US and have never seen a higher concentration of moose. That matters here because the agency's own record is not neutral on what roads do to moose. The DEIS notes moose are drawn to road corridors for road salt, which increases human-moose interactions and conflict. The Tribal Summary Impact Statement credits the rule's protection with the recovery of deer and moose populations in Alaska by preserving old-growth winter shelter. If the agency is aware that road access draws moose into conflict zones and that roadless protection supports population recovery, I ask that it explain how rescission is consistent with those findings.
On water, our situation is direct. Snowmelt is our largest source of water. Opening up these canyons to logging or mining could dramatically affect our water quality and could dramatically increase costs of water treatment. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres. The people drinking water that starts in those watersheds are not a small constituency. The agency must address the water treatment cost consequences of rescission on the record.
On fire, the agency's own record cuts against the proposal. "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 while its own DEIS reports far higher fire density on roaded land than inside these areas. The agency must reconcile those findings with the decision it is proposing.
The proposal also overstates what the rule actually prevents. The text of the rule reads: "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)." If the agency's true concern is permitting burden or access for legitimate uses, those exceptions already exist. I ask that the agency identify, specifically and on the record, which burdens are not already addressed by those provisions, and that it quantify them.
The small-business analysis in this proposal does not hold together. "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." Spreading an annual expenditure loss across every small firm nationally rather than examining the outfitters and guides actually permitted in these areas is not analysis. It is evasion. The certification should be withdrawn and replaced with an assessment of the businesses actually operating in the affected areas, including in the Wasatch-Cache and Uinta national forests where we recreate.
Finally, we have raised children in these places. We hiked in all of these areas with our kids when they were growing up. They are now adults and ready to have their own kids. Our grandchildren may not have the same opportunities as our kids did. That is a reliance interest. "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." The agency invited these interests and then declined to weigh them. It must identify and weigh the reliance interests described in the comments it receives, including this one.
I am a backcountry enthusiast, fishing and hunting maniac, and a proud conservationist. I am equally an American patriot. As such, you will not be surprised to know that I vehemently oppose the rescission of the Roadless Rule, which protects a mere 59 million acres of forest out of the 193 million under USFS management. Yes, the presence of roads on USFS land have a positive correlation with forest fires, and yes, roads can negatively affect forest management practices. That said, I will let other commenters touch on those points of contention, and will exclusively address one item gravely threatened by the potential rescission of the rule: the American spirit. The backcountry and natural world played foundational roles in the lives of our founding fathers and most honorable American men. They served as media through which great American leaders first instilled values of care and stewardship in our country and Western Society. If you think otherwise, I refer you to the early writings of Washington as he traversed the western frontier of land that eventually became Virginia, West Virginia, and Ohio, virtually anything written by Teddy Roosevelt, or Jefferson's journaling on the importance of agrarian stewardship. These men injected an intangible ethos of respecting the natural world into what became the American blood — blood that knows no race or religion and courses through every National Park visiter and hunting and fishing license owner. In 2026, opportunities to respect and interact with an untouched natural world are few and far between. The following phenomenon is a reality of the modern world: the presence of development, cars, and people per acre of American land increases each year. The Roadless Rule keeps 59 million acres safe from that phenomenon, and if we lose it, our nation will lose its attachment to its values gifted by Washington, Jefferson, Roosevelt, and many other men and women. What happens when there are no opportunities to interact with and care for the untouched natural American landscape? Will the American progeny care about the men and women before it who braved the frontier to establish comforts of modern life? Will it care about the beauty and intensity of life without modern comforts, as witnessed through the scent of an old white pine, a lahontan cutthroat in a shallow pool during summer, the mountain laurel in its beauty during springtime, the red oak during fall, an eastern tree frog traversing the forest floor after rain, or a covey of valley quail braving high winds under a toyon tree? The answer to these two rhetorical questions is an obvious "no." In other words, future generations will lose the intangible value of stewardship that our founding fathers injected into the American spirit. The Roadless Rule protects this component of the American spirit from being lost, and I am willing to defend the American spirit with my life. I thus beg the administration to resist rescinding the Roadless Rule so that we Americans do not lose a respect for the natural world that fundamentally shaped the development of our nation and its spirit. Thank you.
Opposes rescissionA3 weakSubstance 10/24Owed an answerSep 14, 2026FS-2025-0001-391757
PLACESTANDDOCGAPEVIDASKALTLAW
Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that the agency respond to each of the following points in the record.
As a retired forest ecologist and faculty member who spent much of her career working on old growth and late successional forests (LSOG), I am particularly concerned about loss of LSOG and biological legacies such as snags and coarse woody debris. In 2006, I led the National Commission on Science for Sustainable Forestry workshop on old growth in the Upper Midwest, which brought together 32 old-growth researchers. Our report was published as NCSSF Project C10.4: Great Lakes Old Growth Workshop, June 2006. We found that less than 1% of the pre-cutover era old growth remains in the Upper Midwest, with particularly sharp declines in hemlock, yellow birch, and white pine, and that fragmentation, road building, and invasive species rank among the major threats. We further found that all remaining old growth and late successional forest on public lands in the region requires protection. I ask that the agency identify what measures, short of retaining the rule, will protect remaining LSOG forests in the Upper Midwest and across the nation.
The National Commission on Science for Sustainable Forestry workshops also found that retention of biological legacies such as snags and coarse woody debris on the forest floor are important for reducing fire risk and protecting soil biodiversity. I ask that the agency quantify the expected loss of snags, coarse woody debris, and other biological legacies if the roadless rule is rescinded and clarify plans to retain these biological legacies for ecological resilience.
Our local roadless area on the Ottawa National Forest is the Norwich Plains Revised Roadless Area. I frequently walk, bird, botanize, and watch wildlife in this area, and it is precious to me. At 4,360 acres, it is small but still important for local recreation (the North Country Trail is contiguous to it) and for the Ontanagon River watershed. I am concerned about species still in recovery here, particularly gray wolves and martens. The DEIS cites the finding that wide-ranging mammals "have suffered habitat loss and the extirpation or fragmentation of their populations," and documents that marten populations decline when forest cover thins, 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, with 31 percent of species avoiding the noise entirely. I ask that the agency explain, on the record, how rescission is consistent with its own documented findings on habitat fragmentation and road-induced wildlife displacement.
Water quality is particularly important for people and for fauna in the Upper Peninsula. Roadbuilding increases sediment flow into tributary streams, which can degrade spawning habitat for trout and other aquatic fauna. As the agency's analysis notes, roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale, and sedimentation from harvest can promote excessive substrate movement, causing egg and juvenile mortality and reduced suitable habitat for fish. The agency must identify what measures, short of maintaining the rule, would prevent sediment loading in these watersheds at the level its own data describe.
Sincerely,
Dr. Nancy Langston, Distinguished Professor Emerita, Michigan Technological University
Chassell MI 49916
Opposes rescissionA3 weakSubstance 8/24Owed an answerSep 12, 2026FS-2025-0001-358014
PLACESTANDDOCGAPEVIDASKALTLAW
Dear Chief Tom Schultz,
I write in opposition to the proposed rescission of the Roadless Rule as a birder and wildlife conservationist, as well as a homeowner with beloved cabins in a National Forest in Northern Wisconsin. I am familiar with the scientific findings, much of it generated by the federal government, that indicate that roads fragment forests, which affects the ability of birds to successfully breed. Roads also make wildfire more likely, not less. The science points against rescission of the Roadless Rule.
The region surrounding Wheeler Lake was heavily logged during the late 19th and early 20th centuries. Initial harvests focused on virgin white pine from approximately 1835 through the 1860s, followed by hardwoods such as maple and oak. The Holt Lumber Company operated a specific line known as the Wheeler Spur, which ran a few miles south from Townsend toward the lake region. By the 1920s, the land was described as "over-cut, burned-over, and farmed-out." Much of the land became tax-delinquent and was abandoned by owners.
The Roadless Rule has protected the Wheeler Lake Islands area from logging and logging roads for 25 years. The diversity of habitat and wildlife in this area is spectacular and too precious to lose. t's taken a hundred years for this area to recover from heavy logging. It’s now a beautiful area beloved by many. Let’s not ruin it again.
If logging roads cut through this area the probability of wildfires will increase, not decrease.
Roads are where most wildfires start. A 2026 study covering 30 years of wildfire data across the entire National Forest System found that wildfire ignition density within 50 meters of roads was nearly four times higher than the average for non-wilderness, non-roadless forest lands. Wilderness areas and Inventoried Roadless Areas had the lowest ignition densities of any category studied (Aplet et al. 2026). — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2)
Most ignitions near roads are human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Wimberly, 2012 (https://doi.org/10.1016/j.apgeog.2011.09.004); Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2)
Regarding the 09184 - Wheeler Lake Islands in the Chequamegon-Nicolet National Forest, Wisconsin:
"From a sample of 463 nests of 17 songbird species, we evaluated how landscape features (distance to forest edge, unpaved roads, and power lines) influenced daily nest survival. For all nesting species combined, distance to unpaved road was the model that most influenced daily nest survival. Numerous nest predators, including brown-headed cowbirds, mammalian mesopredators, and snakes, have been shown to preferentially occupy habitat edge over interior. Rat snakes were frequently associated with road edges, indicating that not all edges are functionally similar."
— Ecology and Evolution (PMC), 2014
“The Roadless Rule does not replace forest plans. It supplements them — adding a layer of protection against road construction and most commercial timber harvest across all 44.5 million acres of inventoried roadless area, regardless of what the underlying forest plan would otherwise permit (USDA Forest Service 2001)”
This comment is against rescission.
Thank you,
Margaret Poethig
Opposes rescissionA1 strongSubstance 14/24Owed an answerSep 2, 2026FS-2025-0001-305095
PLACESTANDDOCGAPEVIDASKALTLAW
I live in Cottonwood Heights, Utah, and I backcountry ski and trail run in the inventoried roadless areas of the central Wasatch, including White Pine, Mineral Fork, and the Millcreek drainages on the Uinta-Wasatch-Cache National Forest. I oppose the rescission and ask the Department to select the no-action alternative.
The stated purpose is wildfire risk reduction, but the 2001 rule already allows cutting and removal of small-diameter trees to reduce the risk of uncharacteristic wildfire, and it has never restricted fire suppression. If those exceptions are too narrow in practice, amend them. Full rescission also strips protections governing mineral development, timber sales, and ski area expansion, none of which relate to fire. The DEIS does not explain why that is necessary.
This makes the range of alternatives inadequate under NEPA. The Department has not analyzed an alternative that broadens the fire and fuels exceptions while keeping road construction prohibitions in place. Idaho and Colorado both have state-specific roadless rules built for exactly that purpose. I request that a Utah-specific alternative, or a targeted amendment to 36 CFR 294.13, be analyzed in the final EIS.
The DEIS should also identify how many acres of planned, funded fuels treatment on this forest have actually been blocked by the rule since 2001. Without that, the purpose and need is unsupported. Most Wasatch roadless terrain is steep and high elevation, where roads are impractical and treatment does little for structures along the Wasatch Front.
Finally, roughly 80 percent of Salt Lake City's watershed sits within this forest. Forest roads are a leading source of sediment in forested watersheds, and the DEIS does not adequately analyze that risk to the drinking water of over a million people.
Please retain the 2001 Roadless Rule.
Christian Purdy
I am writing as a Salt Lake City resident to oppose the proposed rescission of the 2001 Roadless Rule. I live in the Avenues, at the base of the Wasatch, and roadless national forest land is not an abstraction to me. It is where I backcountry ski all winter, where I hike, and where I bikepack. I am asking the Forest Service to withdraw this proposal and keep the Roadless Rule's protections in place, including on the Uinta-Wasatch-Cache and Manti-La Sal National Forests here in Utah.
Recreation: The roadless canyons above Salt Lake City, including areas like White Pine, Mineral Fork, Dog Lake, and Elbow Fork, are the backbone of the region's backcountry skiing. Their undeveloped character is exactly what makes them worth skiing: no roads, minimal crowding, and terrain that has not been fragmented by logging infrastructure. Farther south, the Manti-La Sal National Forest and trails like the Kokopelli, which I have bikepacked, depend on the same undeveloped backcountry character. Opening these areas to road construction would permanently change the experience that draws people to them in the first place.
Water quality: Big and Little Cottonwood Canyons are municipal watersheds that supply drinking water to the Salt Lake Valley. Roads are one of the largest sources of sediment and erosion into forest streams. Keeping these upper watersheds roadless is a direct, low-cost way to protect the water quality that hundreds of thousands of people downstream rely on.
Wildfire: I understand the proposal is framed around reducing wildfire risk, but the evidence points the other way. The large majority of wildland fires nationally are human-caused, and human-caused ignitions are concentrated near roads and access points, not in remote roadless terrain. Utah's own 2024 Yellow Lake Fire in the Uinta Mountains, which burned over 33,000 acres, was ignited by a commercial logging operation, not by a lack of road access. More roads mean more vehicle traffic, more equipment, and more opportunities for human-caused ignition in places that currently see very little of it. If the goal is genuinely to reduce wildfire risk, the answer is targeted fuels treatment and prescribed fire, both of which are already allowed under the existing rule, not a blanket rollback of roadless protections.
For these reasons, I urge the Forest Service to withdraw the proposed rescission and retain the 2001 Roadless Rule in its entirety, including for Utah's national forests.
Thank you for considering my comment.
Ally Johnson
Salt Lake City, Utah