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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.