Read the comments.

I object to rescission of the roadless rule and support Alternative 1, no action, due to the impacts of invasive plant species. I live adjacent to public lands in Eastern Idaho and Western Wyoming where invasive plant species have become a serious concern. In my own experience, trails in Wilderness and Wilderness Study Areas like the Gros Ventre Wilderness, Southern Wyoming Range, and Palisades Wilderness Study Area have very few occurrences of species like Musk Thistle, Canada Thistle, and Spotted Knapweed while roads and trails open to motorized use have populations from occasional individuals to full-blown infestation. One grazing lease adjascent to our farm in Victor, Idaho, on BLM land with a road easement through it, is absolutely infested with Musk Thistle, threatening the economic viability of the lease, spread to the adjacent Targhee National Forest, and increased wildfire risk. It is an economic disaster happening in slow motion. For the specifics of the proposed rescission, my objection rests on the fact that Alternatives 2 and 3 would be in direct conflict with a standing executive order. This order, Executive Order 13751, commits agencies to avoid worsening the problem of invasive plant species and the USFWS’s own Biological Assessment makes clear that roads (and their construction) “create favorable conditions for invasive plants by providing light gaps, dispersal corridors, and reduced competition.” This analysis also states that 60 percent of taxa studied are threatened by invasive or non-native species. The DEIS does not include this finding, nor the 60 percent figure. The DEIS openly admits on page 116 that Alternatives 2 and 3 “could potentially increase the extent or the number of incisive plant species in the affected environment area." This contradiction must be resolved. All of this is to say the obvious: roads bring with them invasive plant species that, once established, are very difficult to deal with and cause significant economic damage. In my area, rescission of the roadless rule would threaten the economy of our valley which relies heavily on recreational tourism. It would also potentially increase wildfire risk. Our functional forest ecosystems are a resource we can't afford to lose.

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

Thank you for the opportunity to comment on the proposed Roadless Rule Rescission. I enter my comments as an individual who enjoys many recreational hobbies that make use of the Forest system. In general I support the stance of the International Mountain Bicyling Association, however the fundamental issue with Roadless Rule is that any top-down national rule does not adequately address State and local variables. Compromise will always be necessary but the blanket rules guarantee that this use conflict is needlessly broad. What is ideal for Colorado isn't necessarily for West Virginia, Alaska or New Hampshire. Nor is indeed what plans work in a very busy National Forest near Denver going to work for a remote Forest near Craig. The USFS recognizes this, which is why Colorado and Idaho needed specialized Roadless plans already. Why not apply this system-wide so that each state or region the ability to develop similar Roadless plans that are tailored to their needs? I would suggest that the Roadless Rule being rescinded would be tolerable and perhaps an opportunity for improvement in some areas such as fire preparedness with a few important caveats. That USFS needs a set of guidelines that give local Forests and offices a clear framework from which to start. From my position as a mountain biker who enjoys exploration and dispersed camping having a Roadless Area turn into a Wilderness, Wilderness Study Area or Area of Critical Environmental Concern would be as equally undesireable as having it clear cut logged and the trails fragmented by new or reactivated roads. I can easily envision loss of Roadless Area designation as an advantage leveraged by both sides of the political land use spectrum to wildly opposing ends. I'd also like the USFS to require state and local managers who wish to change an existing Roadless Area execute an inventory audit and follow a procedure that all stakeholders have ample opportunity to review and comment. In summary I appreciate that Roadless Areas exist as a middle ground between Wilderness and general use recreation and extractive areas. So if the Roadless Rule is to be rescinded I urge the USFS to first have in place guardrails to prevent system-wide chaos. ‭

I'm writing to ask that you oppose the rescission and/ or alteration of the Roadless Area Conservation Rule by following Alternative 1: No Action. I live in Idaho, and spend much of my time working and recreating in roadless areas throughout our state and across the way in Wyoming. I've worked as a wildlife technician for many years in Idaho and Wyoming in the Palisades Wilderness Study Area, throughout the Gros Ventre mountains, in the Wind River range, and in countless other areas throughout both states. These spaces provide irreplaceable shelter and resources for Common Loons, Great Gray Owls, American Goshawks, Wolverines, Golden Eagles, Black Rosy-Finches, and countless other flora and fauna, all of which I have worked to conserve and have relied on for my own professional livelihood. The Roadless Area Conservation Rule has protected the sanctity of these wild spaces, and continues to be one of the most popular and unanimously agreed upon pieces of legislation in the history of our country. With over 600 public hearings, and 1.8 million public comments, the 2001 ruling was heavily favored by the American people and politicians, alike. The ruling continues to see support within the House and Senate to this day, with many lawmakers from both red and blue states voting in favor of legislation that would indemnify the Roadless Area Conservation Rule from future roll-backs. Many of my most cherished memories took place on land protected by the Roadless Area Conservation Rule, and I've built my entire career around the protection of species that rely on them, myself being one of them. Please keep the Roadless Area Conservation Rule in place by supporting Alternative 1: No Action.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting means something to me. It encapsulates American freedom, something people in this country have done for centuries. Fishing is the same: my grandfather taught me, I fish with my wife, and I want to pass it on to my kids. We hike and camp all the time, going for solitude and to build memories. These are not abstract values. They are the reason I oppose the rescission of the 2001 Roadless Area Conservation Rule, and I ask this agency to take my comments seriously. The areas I care about sit inside the Gallatin and Beaverhead-Deerlodge National Forests in Montana. The Bridger unit at 45,059 acres, the Hyalite-Porcupine-Buffalo Horn Wilderness Study Area at 143,991 acres, the Madison at 127,859 acres, and the North Absaroka at 159,075 acres form part of the northeastern wall of the Greater Yellowstone Ecosystem. The Potosi unit at 5,194 acres in the Beaverhead-Deerlodge is part of that same landscape. The Gallatin Range fight has been one of the most contentious roadless battles in the country, pitting backcountry hunters and wildlife advocates against timber interests in grizzly bear habitat. I am one of those hunters. If you hinder hunting, you hinder freedom. America is not about hindering freedom. I have seen streams and trout populations change because of roads and logging. That experience is not abstract either. The agency's own record confirms what I saw. 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 and negatively impact fish such as bull trout by causing egg and juvenile mortality and reduced suitable habitat. Yellowstone cutthroat trout are verified species of the Custer Gallatin. Across the Northern Region, which includes Montana, 1,287 municipal water intakes sit in watersheds containing affected roadless areas. This decision directly impacts streams, where our water comes from, the water we need to drink, the water that fish live in, that cattle drink, the water that our crops depend on. I ask the agency to explain how opening these watersheds to new road construction can be squared with its own data on sediment loading and the public water supplies that depend on these drainages. The economics of this proposal do not hold up 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." The agency is already carrying a $6.9 billion road maintenance backlog against a road budget of roughly $73 million a year. Building more roads into country that has none, when the agency cannot manage the roads it already has, is straight up financial nonsense. Some of these places are not even worth logging, and if you have ever actually been in some of them you would know that. The agency must reconcile its own cost-benefit analysis, which projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value ranging from negative $92 million to positive $199 million, and explain how that uncertain arithmetic justifies expanding a road system whose deferred maintenance is already a crisis. The agency also argues that rescission is needed for wildfire management. Its own record says otherwise: "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 agency must reconcile its proposal with that finding and explain why it departs from the ignition data in its own DEIS. The proposal argues that state-by-state approaches can replace a national rule. The record reflects that the agency itself once described its dissatisfaction with the rule's approach, quoting its own language about rejecting "inflexible 'one-size-fits-all' nationwide rulemaking." But the Ninth Circuit already found problems with the state-by-state replacement the agency tried before. The agency must address how this proposal avoids those same deficiencies. Public lands can host recreation, raw material extraction, farming and ranching, and gathering. All of these are good things, and they can occur without repealing the Roadless Rule. Montana holds 235 inventoried roadless areas totaling 6,395,392 acres. That is a legacy worth keeping intact. Sincerely, Jacob Trausch Bozeman, Montana

My wife and I are hiking users of the trails in the West Pioneer Wilderness Study Area of Southwest Montana. We greatly appreciate the roadless and motorless enjoyment this gives us elderly people. We hope very much that it remains as it is.

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

As an avid outdoorsman for over 6 decades, I hope to continually use Wilderness Study Area backcountry. Please keep these current policies focused on maintaining wilderness and backcountry character and intact wildlife habitat. It is crucial that these lands continue to be managed to conserve their natural, undeveloped state and the high-quality fish and wildlife habitat that make them so valuable to me and my family for hunting, fishing, and other backcountry pursuits. Thank you for your time regarding this very important matter. Gerry Maney

Dear Secretary Rollins, I am a wild-spaces user. By winter, I cross-country ski on established trails, USFS trails, BLM trails and Wilderness Study area. I also alpine ski on national forest land at my local ski area. I strongly oppose the Proposed Rule rescinding the 2001 Roadless Rule. Rolling back the Roadless Rule will open irreplaceable Montana landscapes up to large-scale logging, road construction, and other development that will industrialize our national forests. The Roadless Rule has protected irreplaceable roadless values while permitting fire suppression, fuels mitigation work, trail maintenance, and other forest management activities for the past 25 years. It is a fiscally responsible, environmentally sound, multiple-use management tool. What we don't know until researchers discoveries is what medical cures may derive from untouched wild places. Think toxil. Taxol (paclitaxel) is a landmark chemotherapy medication originally discovered from the bark of the Pacific yew tree (Taxus brevifolia) that revolutionized cancer treatment according to the National Cancer Institute. In the 1960s, a USDA botanist collected bark samples from the Pacific yew tree in Washington State as part of a joint National Cancer Institute (NCI) and USDA plant screening program. What will we miss for medical breakthroughs if we lose roadless areas? Please adopt the No Action alternative for the Final Rule. Sincerely, Jean Arthur-Sellegren Montana

I am an environmental scientist and hunter living in Jacksonville, Florida. I strongly oppose fully or partially rescinding the 2001 Roadless Area Conservation Rule. I support smart development, small businesses, American manufacturing, and growth in American GDP. Those priorities require fiscal discipline and responsible stewardship. Rescinding roadless protections is short-sighted, and the projected timber revenue does not adequately justify the potential public costs. USDA estimates $5.2–$11.4 million in additional annual revenue to the Treasury and Forest Service, plus $4.6–$10.6 million to the timber industry. Yet the agency acknowledges that the harvest scenario underlying these estimates is unlikely to be fully realized because of budget, operational, and market constraints. The same proposal estimates potential losses of $6.1 million annually in economic benefits to recreationists—equivalent to approximately 54%–117% of the projected federal timber receipts. These are different economic measures, but their relative size demonstrates why timber revenue alone cannot establish a net public benefit. USDA also identifies a $6.9 billion deferred-maintenance backlog for roads and bridges. The projected additional annual federal timber revenue equals just 0.075%–0.165% of that backlog, before considering new obligations. Adding roads requires a credible accounting of construction, maintenance, erosion control, restoration, and eventual decommissioning costs—and an explanation of who will pay them. Hunting and fishing already support substantial economic activity. The U.S. Fish and Wildlife Service reports that Americans spent $99.4 billion on recreational fishing and $45.2 billion on hunting in 2022: $144.6 billion combined. Wildlife watching generated another $250.2 billion in expenditures. These nationwide figures are not attributable solely to roadless lands, but they demonstrate the economic importance of healthy habitat and quality outdoor experiences. Forests also provide services that never appear on a timber-sale receipt. Forest Service research estimates that national forests and grasslands contribute 5.2 trillion gallons of surface water annually to public water supplies, with an estimated $47 billion in annual value associated with avoided treatment, dredging, and water-quality violation costs. This system-wide estimate is not a forecast of losses from rescission. It shows why watershed protection belongs in a complete economic assessment. USDA should quantify the incremental risks to these benefits rather than treating benefits that are difficult to price as worth zero. It should also distinguish gross receipts from net fiscal returns and evaluate cumulative costs over the full life of any resulting development. This issue is personal. I routinely hunt and take pleasure in the Osceola National Forest, just west of Jacksonville. Forest Service inventory figures identify approximately 20,737 acres of inventoried roadless areas there, including Pinhook, Impassable Bay, and the Natural Area Wilderness Study Area. These places are part of the landscape I know and value. The opportunity to hunt and experience quiet country away from roads, vehicles, and heavy equipment cannot be fully captured by spending statistics. Access matters, but so does the character of the place being accessed. Development can diminish the very qualities that make a landscape worth visiting. If there is one thing America has no shortage of, it is roads. The Forest Service’s infrastructure assessments describe approximately 370,000 miles of them. We should maintain existing infrastructure while conserving places where Americans can still experience undeveloped country. Wildlife and wild places also have intrinsic value beyond their commercial uses. The North American Model of Wildlife Conservation recognizes wildlife as a public resource managed on behalf of all citizens. That responsibility extends to future generations and the habitats wildlife needs to survive. As Theodore Roosevelt stated: “I recognize the right and duty of this generation to develop and use the natural resources of our land; but I do not recognize the right to waste them, or to rob, by wasteful use, the generations that come after us.” Please retain the Roadless Rule and reject full or partial rescission that weakens its protections. Protecting clean water, wildlife, outdoor traditions, and our shared natural inheritance is sound stewardship and responsible economic policy.

As an avid outdoorsman for over 6 decades, I hope to continually use Wilderness Study Area backcountry. Please keep these current policies focused on maintaining wilderness and backcountry character and intact wildlife habitat. It is crucial that these lands continue to be managed to conserve their natural, undeveloped state and the high-quality fish and wildlife habitat that make them so valuable to me and my family for hunting, fishing, and other backcountry pursuits. Thank you for your time. Gerry Maney

I have lived in Weaverville, NC for 15 years. I cherish the time I am able to spend walking the trails of Craggy Gardens and the Craggy Wilderness Study Area. The serenity of the Mountains-to-Sea Trail is restorative and soothing. I seek out these places to escape the noise and pollution of our city roads. Putting roads through these pristine places will destroy them forever. Roads will destroy the habitats of the wildlife that call these areas home. We share these spaces with owls, with bears, with countless insects, and countless species, the very diversity of which makes our live and environment viable. Especially now, with climate change threatening our planet, we need to safeguard our wild places from the risk of wildfires. Opening our forests to roads and logging won't help. This may, in fact, make it worse. Please -- don't do this. The damage will be immeasurable and irreversible. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

My name is Heather Myers and I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in Bozeman, Montana, and I work as an outdoor instructor. I travel in many areas protected by the roadless rule for work and recreation. I hike, ski and paddle in the Bridger, Hyalite-Porcupine-Buffalo Horn Wilderness Study Area, Gallatin Fringe, Madison and North Absaroka roadless areas around Bozeman for fun, and I also teach avalanche courses in these areas. I lead wilderness trips for an outdoor school in the Togwotee Pass, Pacific Creek-Blackrock Peak, Dunoir Special Management Unit, West Slope Winds, Middle Fork, West Slope Tetons, Phillips Ridge and Wilderness Study Area roadless areas in Wyoming, the Palisades and Lemhi Range roadless areas in Idaho, the Dark-Woodenshoe roadless area in Utah and the College Fiord roadless area in Alaska. I am concerned about damage to ecosystems and impact to fish and wildlife habitat and migration corridors in all of these areas, as well as degrading water quality in many headwaters areas that serve mountain towns (like Bozeman, whose primary water suppy comes from the Hyalite-Porcuine-Buffalo Horn Wilderness Study Area). Native trout in Montana rivers and streams could also be impacted by increased sediment due to road construction and logging, such as native Westslope Cutthroat Trout on the Madison River, which are a species of special concern and currently the subject of a Montana Fish, Wildlife and Parks conservation project. The Madison roadless area is a big part of the Madison River watershed, and development and resource extraction there could have a large impact on the water quality in the Madison River. Lynx in the Bridger Range would also lose habitat, as would Grizzly Bears in the Hyalite-Porcupine-Buffalo Horn and surrounding mountains. I am also concerned about the impact on recreation in wild places with limited human impact-- damage to the ecosystems and the intrusion of industrial activity would have an enormous effect on the experience people are able to have in these places. As a hiker, skier and paddler, I am passionate about these forms of recreation, and as an outdoor instructor, rescission of the roadless rule would directly impact my livelihood by degrading the pristine places I lead trips in-- people come on the trips I lead to experience the grandeur and wildness of these places, and roads and industry will severely compromise the experience of backpacking in those places. Not only would I be personally affected, the recreation industry is a large economic sector in the United States, and particularly in the Mountain West. Losing these wild places will directly impact the outdoor industry in many towns in Montana, like Bozeman, Ennis, Livingston, and Big Sky, as well as Lander, Pinedale and Dubois in Wyoming, and many others in Utah, Alaska, Idaho, and elsewhere. Mining and oil and gas extraction especially concern me, as the potential for pollution and severe degradation of ecosystems is high. The release of mining waste into the Animas River in the 2015 Gold King Mine waste water spill had huge and ongoing impacts on fish and aquatic life, water quality in municipal water supplies in downstream communities such as Durango and parts of Navajo Nation, and made the river unsafe for recreation. Exchanging temporary profit from resource extraction for the ongoing conservation and recreation value of these landscapes is short-sighted. I urge you not to partially or fully rescind the roadless rule. The potential damage to ecosystems, natural places for recreation, and water quality for municipal use and aquatic ecosystem health is too great. Thank you for your time and consideration. Sincerely, Heather Myers

Dear USDA Leadership: As an angler, I don't oppose road-building everywhere. I oppose road-building in country where the rule already said no, the science still says no, and the agency hasn't shown why the answer should change. The 2001 Rule has been a quiet, working piece of policy for two decades. The Department doesn't have to do anything dramatic — just leave it in place. Visiting the Wilson Creek and Harper Creek Wilderness Study Area is one of my favorite backpacking and fishing trips I've ever take. The remoteness was humbling. The Harper Creek Wilderness Study Area was one of the harder, more remote hikes I'd done at the time and gave me a great appreciation for how important it is to have these kinds of places. Regarding the Harper Creek in the Pisgah National Forest, North Carolina: “The area remains a Wilderness Study Area despite being recommended for full Wilderness designation by the U.S. Forest Service since 1987 and having bipartisan congressional support in the 1990s. On December 16, 2001, the area was protected under the Roadless Area Conservation Rule, which designated it as an Inventoried Roadless Area comprising 7,325 acres.” “Large-scale railroad logging commenced in the region around 1910. More significantly, the area became a major site for uranium prospecting from the 1950s through the 1970s. The North Harper Creek Prospect underwent extensive core drilling. Exploration identified uranium deposits in the Wilson Creek Gneiss, with speculative resources estimated at 4 to 8 million pounds of U₃O₈. The remoteness and expense of mining in this area is what has saved it.” “Influence of water exchange and dissolved oxygen in redds on survival of steelhead trout embryos. Survival of embryos relates positively to dissolved oxygen and apparent velocity of intragravel water, and positively to gravel permeability and gravel size. — USDA Forest Service — Forest Roads: A Synthesis of Scientific Information, 1961 (https://doi.org/10.1577/1548-8659(1961)90[469:IOWEAD]2.0.CO;2)” “Sediment production from road surfaces was measured on gravel-surfaced forest roads. Road surface erosion rates were found to be substantially elevated compared to undisturbed forest conditions, with sediment production directly related to traffic levels, road surface material, and road gradient. — USDA Forest Service — Forest Roads: A Synthesis of Scientific Information, 1984 (https://doi.org/10.1029/WR020i011p01753)” “Water and sediment inputs are fundamental drivers of river ecosystems, but river management tends to emphasize flow regime at the expense of sediment regime. Managing for a desired balance between sediment supply and transport capacity is not only tractable, given current geomorphic process knowledge, but also essential because of the importance of sediment regimes to aquatic and riparian ecosystems, the physical template of which depends on sediment-driven river structure and function. — BioScience / Oxford Academic, 2015 (https://doi.org/10.1093/biosci/biv002)” In earnest, CommentID: RLC-20260906-JAUUAF

Re: Docket No. 2026-16965 – Special Areas; Roadless Area Conservation – Please select No Action Alternative and retain the 2001 Roadless Rule My name is Romulus Hiner, I live and hunt out of Harlowton, MT. I hunt the Helena-Lewis and Clark National Forest, Musselshell Ranger District, which is managed out of Harlowton. Three years ago I was lucky enough to draw the 411-20 either-sex elk tag in the Big Snowy Mountains. Anyone who hunts central Montana knows 411-20 is notoriously hard to draw. The unit is dominated by private land, and without the Big Snowy Mountains block of National Forest — including the Big Snowy Wilderness Study Area and Inventoried Roadless Areas — it is nearly impossible for a public-land hunter to have a quality hunt at all. That tag is the reason I care about the Roadless Rule. In the Big Snowies, the lack of permanent system roads is what creates elk security habitat. It keeps elk on public land during rifle season instead of pushing them immediately onto private where access ends. That is public hunting opportunity. When you build a permanent road into that block, you don't create more opportunity — you fragment the security cover, you increase motorized disturbance, you spread hunters up every drainage, and the elk leave. The same applies to fishing. The headwater streams coming off the Big Snowies run cold because they are shaded and intact. New roads bleed sediment into spawning beds and warm the water. I support active forest management. I want to see thinning and prescribed burning where it improves forage and reduces fire risk — and the current Roadless Rule already allows that. Montana has treated over 188,000 acres of roadless ground for hazardous fuels under the rule. We don't need to repeal the entire national rule to do restoration work. We need to avoid unnecessary new permanent roads. Repealing the rule would remove protections from 44+ million acres nationally and more than 6 million acres here in Montana, including the island ranges around Harlowton — Big Snowies, Little Belts, Castles, and Crazies — that are our only large low-road-density blocks. I ask the Forest Service to: 1. Select the No Action Alternative and retain the 2001 Roadless Area Conservation Rule. 2. If any changes are considered, adopt a Montana-specific approach like Colorado and Idaho have, that allows restoration but retains core roadless protections and limits new permanent roads. 3. Extend the public comment period beyond September 21, 2026. A 21-30 day window is not enough for hunters, anglers, and rural communities to comment on 6.4 million acres in Montana. The Big Snowy Mountains gave me a once-in-a-lifetime hunt because they were still roadless. Please keep them that way. Romulus Hiner Harlowton, MT 59036

I am writing to voice my opinion that the Roadless Rule should not be rescinded! I view this as another attempt by the current administration to deregulate everything. Nor do I see the proclaimed objectives of new roads for better wildfire fighting access and forest health management being achieved. The U.S. Forest Service (FS) has a backlog of 7-11 billion dollars in deferred road maintenance and with a continuously declining budget deregulation will only exasperate this situation. Neither is there mention of increasing FS budgets to accomplish stated objectives. My backyard is the Big Snowy Mountains which is an Inventoried Roadless Area where road construction or reconstruction is not allowed and is also a Wilderness Study Area (WSA). At a recent public meeting to discuss removing the WSA designation, adjacent landowners to the forest supported this effort to promote logging which could reduce wildfire potential. Those landowners were asked if they would provide/sell an access easement across their properties to FS property, all declined. Nor are there any known resource values (timber, minerals, oil, or gas) of economic value that would justify road construction in difficult terrain there. In 2001, about 1.6 million public comments were received on the Roadless Rule – 90% of which were in support of it. A great example of allowing those on the ground decide local management. Rescinding the Roadless Rule is the opposite, a top-down non-scientific based effort. Again, I am asking that you not rescind the Roadless Rule! Thank you for allowing me to express my concerns and taking the time to read them.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I live near the Bridger-Teton National Forest and the Palisades Wilderness Study Area, and go into almost daily to hike and watch birds and other wildlife. I have a direct stake in what the agency decides here, and I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask the agency to address the specific failures in its analysis described below. The Bridger-Teton holds 19 inventoried roadless areas totaling 1,417,499 acres. It forms the western wall of the Greater Yellowstone Ecosystem, the largest intact temperate ecosystem in the world. The proposal's wildfire rationale contradicts the agency's own data. 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." I lived through the Green Knoll fire some years ago. That fire was overdue, and I am glad that forest managers at the time recognized the importance of letting that, and many other fires burn. The agency's own ignition data point in the same direction the Green Knoll managers understood: roads bring fire risk, not fire relief. The agency must explain why the proposal departs from its own prior findings and must reconcile that departure with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. On biodiversity, the DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is documented and then left floating, unconnected to the 40.1 million acres of potentially affected environment. This forest and our other wildlands should be managed to maintain the maximum sustainable biodiversity and ecological integrity possible. A fragmentation range that wide, applied across an area that large, demands a projection, not a citation. The agency must apply that range to the 40.1 million acres. Finally, on big game: the DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. The elk herds of the Bridger-Teton, including those whose summer range sits in these roadless mountains, are directly implicated. Nowhere in the document does the agency project population-level consequences or estimate effects on hunting opportunity. That gap must be filled before any final decision is made. Sincerely, Brot Coburn PO Box 1022 Wilson, Wyoming 83014

Dear USFS, My husband and I live very close to a wilderness study area. The Hoodoo WSA in Powell County Montana. Last year 2025, lightening started The Devils Mountain fire, easy to happen when there are 4 feet of biofuels on the forest floor. Of course there were no maintained trails nor roads for fire fighters to reach the fire for containment. EVERY WSA, conservation area, and National Forest, should have a fire break/road around it. It is time to do it differently! If you cannot take care of the forest, especially after a beetle invasion, and turn your responsibility away from the dead trees and biofuels, don’t complain about climate change! A forest fire is a climate related risk. And, God knows we have had so many these past few years. Yes, yes, yes, rescind the rule, make those roads, do the forest management projects, call it carbon management, help the high risk forests be more resilient. A fire doesn't care if a forest is inventoried or not, and my guess is, if it is Inventoried it has more to offer a fire. Yes, absolutely YES! Eventually, the Devil Mountain fire grew into the Windy Rock Fire, which was also started by lightening in the same WSA. Two hundred and forty acres of private lands burned. Time for a serious evaluation of future fire mitigation. The Hoodoo WSA was 11,380 acres, more than half of it was burnt up! The most expensive fire in Montana at a price tag of $70 million dollars. That could build a lot of fire roads or breaks. Thank you, for the opportunity to comment. Mary Helen Warren

Resend the roadless rule. The federal government has no right to totally destroy our national forest. For the last 50 years since 1977 with the wilderness study in the pioneer mountains are force turned into a nightmare this year alone 50,000 acres have burnt because the trees just lay on top of one another. These fires destroy our national forest and wildlife. This needs to stop now. The local government not to forest service maintains the trails that we do use. The forest service let these fires burn because they were in the wilderness study area and they got away from them.. just about the whole west side of the pioneer mountains in the last two years have been destroyed. The forest service needs to be revamped or turned over to DNRC for each state to manage the national forest.

I strongly urge that Alternative 1 (no action) of the 2001 Roadless Area Conservation Rule Rescission Draft Environmental Impact Statement be selected. I have quantified changes in ecological health across the Greater Yellowstone Ecosystem during the past 30 years. The results show that most vital signs of ecological health are stable or improving on national park, designated wilderness, wilderness study area, and inventoried roadless area lands but most vital signs are deteriorating on general forest service or private lands. This is because habitats have been destroyed and fragmented due to population growth, home construction, roadbuilding, and increased motorized and nonmotorized recreation on the nonwilderness lands. Wildlife species that depend upon retaining the inventoried roadless lands include grizzly bear, wolverine, wolf, elk, mule deer, pronghorn antelope, and moose. The EIS acknowledges that Alternatives 2 and 3 would degrade habitat for such species. “Under alternatives 1, 2, and 3 any road construction, road reconstruction, and timber harvest could potentially have long-term adverse effects on biodiversity by increasing habitat fragmentation, loss of connectivity, negative edge effects, and human disturbance. These impacts would likely be more frequent and broader in scale under alternative 2. Impacts under alternative 3 would likely have a lesser effect on biodiversity than alternative 2, because the prohibitions on these activities would continue in some areas. Impacts to biodiversity would likely be the least under alternative 1, because current prohibitions allow limited exceptions for these activities” (EIS pg 157). In an America where the area of wildlands and natural habitat is shrinking rapidly, it is critical to maintain Inventoried Roadless Areas in their current protected status.