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My name is Will. I'm 21 years old from Missoula, Montana and I moved to Salt Lake City, Utah to study journalism in college. Now a senior, I fear reduction after reduction of our protected public lands will significantly contribute to the decline of our great nation. Even now, America's natural beauty sets us apart, truly marking us as one of, if not the best country in the world. But as rapid development and a changing climate continue to destroy wilderness areas worldwide, I believe they will soon be a commodity so valuable that we will actually become the richest nation in the world. No more will our wealth be inflated by arbitrary stocks or unethical military might. Not for reasons of extraction or untapped potential, we hold environmental wealth simply for what these wilderness areas are. Tranquil, balanced slices of life. Raw, beautiful ecosystems built by our creator -- something we could never replicate. The Bitterroot National Forest is one of my favorite places in the world and I wish to see it protected for my children and their children. Millions of people feel the same way about various bits of roadless, protected land. In fact, I'm sure you could find at least 1 person who opposes these proposed cuts for every square acre of protected land. Not just general people and random bits of land, I mean specific people who love specific areas and acre plots. Please do what you know is right and protect these areas by rejecting any cuts to the 2001 Roadless Rule. We can build a strong future, and we can make America great again, but cutting environmental protections are not the way to do that. The lands are our lifeblood. They are our past, present and future. We must protect and cherish them at all costs -- it is only human.

I was fortunate to be a strong advocate for the Roadless Rule some 25 years ago. I support the rule and can not image key areas of Montana and other locations not being protected. I often spend time in Montana Roadless Areas - such as the Great Burn area and Burdette Creek in Montana. And I have visited and hikes many other roadles areas. I have property in the Bitterroot National Forest Area and see the first hand the damage roads do to water quality and huge amount of current roads that are not maintained. The harm of current roads in overwhelming in the West Fork of the Bitterroot drainage. The difference in water quality between unroaded and roaded areas in tremendous. The damage is tremendous. Special unroaded areas would see huge damage from roads. And these roads cost the tax payer huge sums - we do not recover these costs from timber sales. The amazing assumption that roading areas will save forest fires is false. CommentID: RLC-20261007-KEWAB6

Roadless Rule Dear Secretary Rollins, I am writing in opposition to rescinding the 2001 Roadless Rule. I support Alternative 1, no action. Undeveloped roadless areas and Wilderness are part of what defines Montana and other western states. They are what makes our state the envy of people from all over our nation and the world. Without them Montana would be just another place. Unroaded areas contain areas of unique special qualities but are not protected by wilderness designation. Many areas are wilderness study areas (WSA) but have been repeatedly blocked from gaining wilderness status by conservative legislatures. Unroaded areas often provide a buffer zone around our wilderness areas and National Parks and Monuments. Imagine if clearcuts or open mines were allowed around the perimeter of Glacier National Park. It has been stated that the purpose of rescinding the 2001 Roadless Rule is to give control back to the local forests and reduce the burden of Washington’s over regulation. But in the body of the Roadless DEIS the following executive orders are found (pages 19-20 I believe): 1.Executive Order 14192: Unleashing Prosperity Through Deregulation 2.Executive Order 14225: Immediate Expansion of American Timber Production 3.Executive Order 14154: Unleashing American Energy 4.Executive Order 14153: Unleashing Alaska’s Extraordinary Resource Potential To me this sounds like an expansion of top-down management rather than bottom-up especially considering other actions we have seen from the current administration. Lastly, some bullet points to ponder: •The Bitterroot National Forest where I live has 2,246 miles of FS roads. For comparison the county, Ravalli, which is surrounded by the forest only has 1,450 miles of road. •Last spring after winter storms closed FS roads with fallen trees, local citizens opened some roads because the Forest Service lacks the resources to do so. •Forest roads are costly to maintain. That is why many are gated and others are in poor condition. Adding more roads will add to the maintenance cost in addition to the initial cost of construction. •Roads contribute to man-made forest fires, the spread of invasive plants, and can have negative effects on sensitive wildlife. Whenever I walk the forest roads in my area I see many invasive plants competing against native species and spreading outward into the forest. •Logging and mining can and does have negative effects on stream and river quality. •Roads are detrimental to recovering animal species such as Grizzly Bears, Lynx, and Wolverines. Roadless areas provide corridors for these animals to move about and expand their range.

One of my favorite places in the state of Montana is the Bitterroot National Forest, largely due to the miles of pristine trails that meander along the mountain tops and beside creeks winding through the many verdant valleys. In the winter, some of these trails can also be used for cross-country skiing, which is an exceedingly popular activity in the Bitterroot Valley and beyond. The National Forest also provides superb backcountry hunting and fishing opportunities that draw visitors from all over the state and beyond for our abundance of elk, deer, and trout. These miles of trails and forest have for years been protected by the Roadless Rule, which safeguards not only the health of wildlife and the environment in undisturbed areas of the country but human health and recreation. A rollback of the Roadless Rule would fragment intact ecosystems, harm wildlife, and increase wildfire risk by bringing in more human disturbance to 18.5 million acres of the Greater Yellowstone Area of Montana, Idaho, and Wyoming alone. According to the National Parks Service, 85% of wildfires in the US are caused by human activity, and introducing more industrialization to these vulnerable areas will only dangerously exacerbate the fire problems we in the western half of the US are already facing. In addition, a repeal would have massive implications for all backcountry recreation and consequently the tourism industry that helps keep rural communities like mine alive. Repealing the Roadless Rule would end protections for 8,659 climbing routes, 768 miles of whitewater paddling, and 25,121 miles of trails across the country, effectively destroying recreational opportunities for millions of people across the country, including myself and my colleagues who are also avid backpackers, hikers, skiers, and rock climbers. Many areas protected by the Roadless Rule also cover vital watershed areas that serve as a home for native species of trout and salmon, both fish that drive a great deal of our local tourism economy, which is dependent on seasonal fly-fishing. The impacts of erosion and pollution from logging and road-building in these areas would be disastrous for these aquatic populations and could drive communities built upon fishing tourism to economic ruin. Finally, habitat fragmentation and wildlife disruption would severely disturb populations of elk that inhabit the National Forest and the neighboring Selway-Bitterroot Wilderness. If these roadless areas of the forest are disturbed, thousands of outdoorsmen would lose a priceless ungulate hunting ground, which once again would have dire consequences for the seasonal tourism industry in my community and in neighboring areas. There is no logical reason to repeal a policy that is so effective in balancing active forest management, conservation, recreational opportunities and rural development. There is nothing to be gained by introducing industrial activities to these areas that would outweigh the irreparable losses to the natural beauty, tranquility, and wellness of our irreplaceable land. Our public lands have widely been regarded as “America’s best idea,” and protecting our natural resources is integral to the identity and cultural of the western US, particularly in the “Last Best Place” of Montana. Due to these factors, I implore you to stop the rescission of the Roadless Rule that has served our lands and our people so well for so long.

I am commenting on the U.S. Forest Service (USFS) proposed rule to fully rescind the 2001 Roadless Area Conservation Rule. Considering the alternatives suggested by the Draft Environmental Impact Statement (DEIS), I strongly urge that the rule be left in place. I am a conservationist who enjoys hiking, hunting and fishing in the National Forests that have been protected by the Roadless Rule for the past 25 years. The exclusion of road construction, reconstruction and timber harvesting has allowed some of our most pristine forests to flourish and remain intact for generations of Americans to enjoy. I live on the east coast and travel 2 out of every 3 years to the western states to recreate in National Forests throughout the Dakotas, Wyoming, Colorado, Utah, New Mexico, Oregon, Washington, Idaho and Montana. I am recharged after spending time in these special places, and I would not want to see changes in the way they are managed in regard to forest roads and timbering. While camping in the Bitterroot National Forest in Montana last summer, I hiked the Nee-Me-Poo Trail to the top of Gibbons Pass. This steep trail gains 1780 feet of elevation over the two mile hike. A section of this trail is historically significant as it follows both the Nez Perce National Historic Trail and the Lewis and Clark National Historic Trail. As I hiked the trail, I could see areas on surrounding mountains where the timber had been harvested and logging roads had been cut in that traversed back and forth across the steep slope of the mountain. It's very possible that this fate could befall the trail that I was hiking on if it was not protected. At the top of the pass, I stood on the edge of millions of acres of the wildest, most rugged land in the lower 48 States - it was a magnificent sight! I camped in the "Indian Trees" campground in the Bitterroot National Forest and slept under the huge ponderosa pines. Some of the largest pines bore the scars from when native Americans peeled the outer bark off the tree to reach the sweet cambium layer below. This was food that kept them alive. The peeling took place on these pines between 1835 and 1890. So much history blended with natural wild beauty. I felt fortunate to be able to experience these mountains and this place. When the Federal Government weakens protections for these special areas, they are not making them more accessible for the public, but more so they are endangering them. These lands are our heritage and should be protected without a second thought. They are already accessible to the public and if anything, the government should be doing more to protect them. Providing enough staffing would enable the Forest Service to properly maintain the forests and allow the work that needs to be done to manage proactively for fires. The Forest Service cannot keep up with maintaining the 370,000 miles of roads that it already manages, why would it expand and construct more roads than it can handle? I don't understand the logic behind making this change and I want to see the Roadless Area Conservation Rule remain in place.

I am writing to urge you to keep the Roadless Area Conservation Rule by supporting Alternative 1: No Action. I have lived in Pierce, Kamiah, Kooskia, within the Wild & Scenic Middle Fork Clearwater River corridor, and, currently live in Moscow. As a long-time resident, recreationist and conservationist who highly values the great historical and wilderness character of our nearby Bitterroot National Forest (NF) and Nez-Perce-Clearwater NF, Frank Church River of No Return Wilderness Area (WA), and Selway-Bitterroot WA. Enjoying and valuing these wild public places is my life-style; it’s part of who I am, and I’m not by a long-shot alone. Thousands of people – Idaho, Wyoming and Montana family, neighbors, townsfolk, as well as tourists and recreationists from all over the country and the world enter these wild places to hike, camp, swim, raft, kayak, ski, bike, horse ride, berry pick, scout wildflowers, practice photography, hunt, fish, bird, and learn and experience Lewis & Clark Expedition and Native American history … or to simply find peace and joy in nature. And they are able to do it all without despoiling the land, the rivers and lakes, nor the plant and animal life. While Idaho operates under its own state-specific roadless rule, the proposed rescission of the Roadless Area Conservation Rule would directly affect the immediate and neighboring national forests and wilderness areas I know and use. These landscapes don't stop at state lines, nor at wilderness and national forest boundaries. Essential wildlife migration corridors, shared watersheds, old growth tree clusters, the trails and legends of Native and non-Native history, and regional recreation economies connect them directly to where I live. The Roadless Rule has proven itself vitally protective. It continues to be supported broadly by millions of Americans. Even right here in logging country, not even the timber industry is asking for its rollback. If there is any agreement between the rural ‘left’ and the rural ‘right,’ the Roadless Rule would be the nexus! In terms of wildfire frequency, rolling back the Roadless Rule will lead to more, not fewer. Research covering 1992–2024 found wildfires were four times as likely to start in areas with roads than in roadless forest tracts, and a separate study found more than 90 percent of wildfires nationwide occurred within half a mile of a road. The Roadless Rule as written already allows the flexibility land managers need. It permits road construction to address fires, floods, or other catastrophic events, and to connect communities. Forest managers routinely conduct stewardship work in roadless areas — prescribed burning, wildlife habitat improvement — under the current rule. These lands are the source of drinking water for downstream communities, home to iconic wildlife including the Yellowstone-area grizzly and elk populations and salmon species for whom Roadless Areas provide crucial sanctuary. These lands are also the backbone of regional outdoor recreation economies. Since 2001, protected roadless areas in Wyoming, Montana and Idaho have supported world-class hunting, fishing, and camping. Millions of Americans use these public lands every year, powering billion-dollar recreation economies across the West. I urge you to reject rescission of the Rule and to keep the 2001 Roadless Rule intact by supporting Alternative 1: No-Action.

Dear USDA Forest Service Planning Team, As an active trail advocate, mountain biker, hunter, and President of the Bitterroot Backcountry Cyclists, I am writing as an individual to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service to select the “No Action” alternative and retain the protections provided by the 2001 Roadless Rule. I have spent many years exploring, riding, hunting, and helping maintain trails throughout the Bitterroot National Forest. Many of the trails and landscapes that I value most are located within Inventoried Roadless Areas (IRAs). These areas provide opportunities for primitive recreation, protect intact watersheds and wildlife habitat, and preserve large, relatively undeveloped landscapes for future generations. In the Bitterroot Valley where I live, many of the backcountry trails that I know and value are located within IRAs. Examples include trails in the Alan Mountain, Sleeping Child, Stony Mountain, Sapphire, Blue Joint, and Selway-Bitterroot Roadless Areas. These include trails such as Warm Springs Creek, Fire Creek, Porcupine Creek, Sleeping Child, Bald Top, Willow Creek, Bitterroot-Rock Creek Divide, Blue Joint, Razorback Ridge, Bare Cone, and Blodgett Canyon. These are not simply areas on a map to me. I have personally explored and helped maintain many of these trails, and I have seen firsthand the value of maintaining their relatively undeveloped character. The combination of dispersed recreation, intact landscapes, wildlife habitat, and a network of primitive trails provides an experience that cannot be recreated once roads and associated development fragment these areas. I am particularly concerned that rescinding the 2001 Roadless Rule would remove an important national baseline protecting these characteristics. I understand that rescission would not automatically authorize road construction or timber harvest in every roadless area; rather, management decisions would increasingly be governed by individual forest plans and other applicable authorities. Nevertheless, removing the national protections would create greater opportunity for future decisions that could introduce roads, timber harvest, and other development into areas that have remained largely intact. Road construction is particularly consequential because a road is not simply another type of forest management activity. Roads can fragment habitat, alter drainage and watersheds, facilitate additional development and motorized access, and change the character of surrounding trail systems and recreational experiences. Once an intact roadless landscape is fragmented by roads, its primitive character is difficult or impossible to restore. I also believe the value of these lands extends well beyond the communities immediately surrounding them. When I travel to other parts of the country, I actively seek out the primitive and relatively undeveloped landscapes protected by the Roadless Rule. These areas are part of a national system of public lands that provides opportunities for recreation, solitude, hunting, wildlife viewing, and other experiences that are increasingly difficult to find. I have focused on the roadless areas near my home because these are the places I know best. However, my concern is broader. I believe the remaining Inventoried Roadless Areas throughout the National Forest System represent an important national resource and should continue to receive consistent protection. For these reasons, I respectfully urge the Forest Service to retain the 2001 Roadless Area Conservation Rule and select the “No Action” alternative in the Environmental Impact Statement. Thank you for considering my comments and for your stewardship of these important public lands.

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

October 4, 2026 Joshua White, Acting Director Ecosystem Management Coordination 201 14th Street SW, Mailstop 1108 Washington, DC 202250-1124 Re: 2001 Roadless Area Conservation Rule Rescission Draft EIS-RIN 0596-AD66 I Marsha Waliser is providing comments on the proposed rescission of the 2001 Roadless Rule (Rule). I support the repeal of the rule and returning decisions for local NFS lands to the local National Forest units. Here in the Bitterroot National Forest many of the “roadless” areas are in fact roaded and were used by us. The Bitterroot National Forest is responsible for the lands under the current Rule in our local area. I have seen these watersheds degrade in their ability to withstand fire behavior and associated effects that presently occur in this climate and landscape. It is disturbing to see high severity fire effects across large landscapes that could have been prevented with proper management. I have also had reduced public recreation access on those same lands that have been used by generations. The taxpayer owns the land and deserves access for all individuals, including the elderly, handicapped and other groups that cannot hike into these areas. When a fire burns the same areas every few years and we then get heavy snowpack or rains the topsoil (plant support) gets washed away causing extreme harm not only to the land but our rivers and streams. Forest wide analysis would determine which acres can be managed and treated and how to best implement those actions. Of course, in the steep terrain on the Forest, some of the acres will naturally remain roadless. The Forest can make this determination with specialists and local expertise. Future project design would take this into account. The locals know how to best manage our forest not Washington. In summary, I support Alternative 2 in the DEIS. We need local management of our Public Lands not controlled by Washington or the Federal Judges. Sincerely, Marsha Waliser 199 Cordial Lane Hamilton, MT 59840

October 4, 2026 Joshua White, Acting Director Ecosystem Management Coordination 201 14th Street SW, Mailstop 1108 Washington, DC 202250-1124 Re: 2001 Roadless Area Conservation Rule Rescission Draft EIS-RIN 0596-AD66 I James Waliser is providing comments on the proposed rescission of the 2001 Roadless Rule (Rule). I support the repeal of the rule and returning decisions for local NFS lands to the local National Forest units. The Bitterroot National Forest is responsible for the lands under the current Rule in our local area. I have seen these watersheds degrade in their ability to withstand fire behavior and associated effects that presently occur in this climate and landscape. It is disturbing to see high severity fire effects across large landscapes that could have been prevented with proper management. I have also had reduced public recreation access on those same lands that have been used by generations. The taxpayer owns the land and deserves access for all individuals, including the elderly, handicapped and other groups that cannot hike into these areas. When a fire burns the same areas every few years and we then get heavy snowpack or rains the topsoil (plant support) gets washed away causing extreme harm not only to the land but our rivers and streams. Here in the Bitterroot National Forest many of the “roadless” areas are in fact roaded and were used by us and I would like to be able to ride these roads before I get too old and disabled. Forest wide analysis would determine which acres can be managed and treated and how to best implement those actions. Of course, in the steep terrain on the Forest, some of the acres will naturally remain roadless. The Forest can make this determination with specialists and local expertise. Future project design would take this into account. The locals know how to best manage our forest not Washington. In summary, I support Alternative 2 in the DEIS. We need local management of our Public Lands not controlled by Washington or the Federal Judges. Sincerely, James Waliser 199 Cordial Lane Hamilton, MT 59840

The following are comments from The Ravalli County Collaborative of Ravalli County, Montana (RCC) on the 2001 Roadless Area Conservation Rule Recission Draft EIS-RIN 0596-AD66. We are a diverse group of dedicated volunteers first appointed in 2018 by the Board of Ravalli County Commissioners to promote the wise use and management of natural resources within Ravalli County. Members of our group are committed to working collaboratively, to achieve balanced decisions that reflect the diverse values of our community. The 2001 Roadless Rule identified approximately 447,000 acres on the Bitterroot National Forest that had not been accessed by constructed roads for timber harvesting up to that point in the history of the Forest. These remaining unroaded areas are highly valued for their wildlife habitat and quiet non-motorized recreational opportunities. But we also recognize that conditions have changed since 2001 and much of the Forest, not just these roadless areas, needs forest restoration and reduction of fire risk to adjacent private property. We believe that none of the alternatives sufficiently address this important and controversial issue. Each inventoried roadless area of the Forest is unique. The current “one size fits all” rule as written may be adequate in one area of the National Forest system and insufficient in another to address management issues that have arisen since the 2001 rule has been applied. There should be a collaboratively developed alternative that outlines a site-specific process that requires each forest to evaluate each area individually. Before boundary changes or more intense management direction is recommended, forest wide values and issues evaluated should include forest health, fuel conditions, wildfire risk, old growth, wildlife connectivity, watershed protection, recreation opportunities, terrain restrictions and access needs. The Chief should direct each Forest Supervisor to identify site specific management direction for each roadless area. The public should be collaboratively engaged to identify where the current direction is adequate, and which ones need the exemptions to be updated and customized to address current management issues. Each Forest Plan should then be amended to formalize direction provided through the Roadless Rule or to modify management direction as appropriate. These areas have such significant value and are so controversial they warrant a deliberate public process to change their future management direction.

I am Maxwell Johnson, a Wildland Firefighter in Idaho who is vehemently and unequivocally opposed to the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. Immediately after graduating high school in Florida, I moved across the country to Missoula, Montana, a place which I had never visited without a family or friend within a 1,000 miles. I came to Missoula for exactly one reason, because it is surrounded by the most pristine wilderness in the lower 48. I am not referring to the asphalt-scarred, overcrowded and endlessly commercialized Yellowstone and Glacier National Parks but rather the untouched roadless areas of Selway-Bitterroot, Bob Marshall and Lolo National Forest. Recreating in these areas and countless others Montana has been my pursuit of happiness. It’s my church and where I practice my religion. It is where I have gone during times where I had nothing left to live for to have my lust for life restored. The repeal of the 2001 roadless act is an existential threat to all of this. It will simultaneously remove restrictions from 405,883 acres in the Selway-Bitterroot NF, 758,433 acres in Lolo NF and over 1.5 million acres in the Bob Marshall Wilderness. Many have written expertly about the catastrophic impact the repeal of this rule will have on the environment and recreation and of these areas and the thought of this devastation has caused me to weep. But today I would like to move past emotional appeals and address the agency's claims about my own field, Wildland firefighting, which I possess the expertise to empirically disprove. The agency's claim that roadless areas have higher fire risk and road access is required to mitigate these fire risks contradicts its own analysis and studies on the subject. I am specifically referring to the text of the proposed rule under “Summary of potential impacts,” subsection “Wildfire Risk” which states, “While greater public access can increase human-caused ignition potential in some locations, the 2001 Roadless Rule's prohibitions have limited mechanical thinning options and some fire control tactics in inventoried roadless areas. Substantial acreage within potentially affected inventoried roadless areas has a relatively high likelihood of burning under high intensity conditions that are difficult to manage or could pose a risk to communities…” The agency provides no further justification for these claims while its own 2020 study titled “Long-Term Forest Health Implication of Roadlessness" conclude, “fire risks are approximately equal inside and outside of roadless areas… with the benefit of twenty years of monitoring, the best available records do not support speculation that roads are needed in IRAs to maintain forest health.” This study includes particularly accurate and complete data of Montana forest and roadless areas in the Selway-Bitterroot, Bob Marshall and Lolo National Forest. I want the agency to explain, specifically and in writing, why it is departing from those prior findings, and to reconcile the rescission with this study. Countless other reports and studies come to the same conclusion with some such as the report “Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads” finding that fires are four times more likely to start within 50 meters of roads than in roadless areas. This was a trend seen across all regions, not just “some areas,” as the proposed rule describes. The study notes the higher rate of ignition is due to human rather than lightning caused fire which according to a study by the agency itself acknowledges these make up 84% of wildfire ignitions, with lightning accounting for the remaining 16%. A 2020 study of California Wildfires found that those human caused fires spread quicker, burn more intensely and kill more trees than lightning caused fires. I again request to know why, specifically in writing, the agency is blatantly ignoring widely accepted and respected data on the subject in its rescission when it claims in direct opposition to it “that inventoried roadless areas have a relatively high likelihood of burning under high intensity conditions.” I have not just read these studies, I have lived and worked them, through smoke choked lungs and calloused hands, through a week straight of 16 hour days, fighting fire. As a Wildland Firefighter, I don’t ask to be paid more than $16 an hour and I don’t ask to be taken care of in 20 years when my lungs and legs will be shot and broken from this work. I do ask that the U.S. government stops its recession of the 2001 rule, so that I may be allowed to do my job free of meddling and so that when the job is done I may have a few good quiet places left upon this earth to rest in. Thank you for your time. Sincerely, Maxwell Johnson Coolin, Idaho

September 13, 2026 My Public Comments on the proposed ‘Roadless Rule’ by the US Forest Service: Idaho is a GREAT State. One quality that most Idahoans love about our state is the outdoor recreation opportunities available to us. These adventures to experience nature abound in Idaho. It is a part of our heritage. We, the people, love these lands and all that they provide for our wellbeing. Let’s talk about the US Forest Service and the ‘Roadless Rule’, passed in 2001. The USFS reasoning behind this rule 25 years ago was 1) ecological importance, 2) overwhelming popularity with the public, 3) economically responsible. All these points are just as valid in 2026 as they were in 2001. In fact, it could be argued that benefits of the Roadless Rule (such as habitat, water quality, and air quality) are more important now. Repealing the Roadless Rule is myopic folly. It would be a harmful decision for our State and our Nation for the foreseeable future. A repeal is not necessary; the USFS currently has too many miles of road to maintain. The preservation of roadless areas is so beneficial for our nation, the people, the flora and fauna, and the natural ecosystems.This August, my wife and I just spent four days in the Selway/Bitterroot National Forest. What a beautiful and sacred place! The public has access now; they don’t need more roads to enjoy this gem of the Gem State. The public needs to know these lands are protected by our government. Forever. Sincerely, Gerald Flatz 1347 S. Tetonia Dr. Boise, ID 83705 GHFlatz@msn.com

To the Roadless Rule Rulemaking Team: As someone who has made a practice of noticing what's actually present in a place, I'd say that what's present in roadless areas is time — accumulated, undisturbed time — and that's the thing you can't put back. This July we spent 5 days in the Bob Marshall wilderness on a trip that tested me and provided a solitude and wildness that deserves to be protected. It was a truly incredible experience of vast forests and rivers and mountains and wildlife and humans along side it all coexisting. Adding roads to an area like this would destroy the ecosystem and fragment one of the few remaining large wilderness areas we have left. The Department should understand that the Rule's rescission would produce real and lasting consequences — not only for the lands themselves, but for the people whose lives have been shaped by access to them. Regarding the Stony Mountain in the Bitterroot National Forest, Montana: NEPA requires analysis proportional to the significance of the proposed action. The Stony Mountain IRA (44,057 acres) in Bitterroot National Forest has unique watershed, habitat, and ecological characteristics that a programmatic EIS addressing 2,332 areas in aggregate does not and cannot analyze. The DEIS treats 2,332 inventoried roadless areas as interchangeable units for purposes of impact analysis, but the Stony Mountain IRA (44,057 acres) in Bitterroot National Forest has distinct ecological conditions that produce site-specific impacts no programmatic document captures. The DEIS must provide site-specific NEPA analysis for the Stony Mountain IRA (44,057 acres) in Bitterroot National Forest, as required by 40 CFR 1502. A programmatic assessment of 2,332 roadless areas does not satisfy the requirement for analysis proportional to site-specific impacts. "Section 404 of the Clean Water Act (CWA) establishes a program to regulate the discharge of dredged or fill material into waters of the United States, including wetlands. Activities in waters of the United States regulated under this program include fill for development, water resource projects (such as dams and levees), infrastructure development (such as highways and airports) and mining projects. Section 404 requires a permit before dredged or fill material may be discharged into waters of the United States, unless the activity is exempt from Section 404 regulation (e.g., certain farming and forestry activities). The basic premise of the program is that no discharge of dredged or fill material may be permitted if: (1) a practicable alternative exists that is less damaging to the aquatic environment or (2) the nation's waters would be significantly degraded." — U.S. Environmental Protection Agency The proposed rollback of the 2001 Roadless Rule jeopardizes nearly 58 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service, comprising around a third of the territory in our national forest system. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Research - Wildlife Habitat” “Tongass roadless areas contain very large biomass and soil carbon stocks, underscoring old-growth protection as a critical climate solution with global significance. — Research - Climate Solutions” Rescission action is opposed; the Department is urged to allow the Rule to stand. With respect, Catherine

I value roadless areas because they provide wildlife habitat, clean water, and places where I like to hike, fish and experience roadless natural areas. Specially I’ve spent time in the Kootenai National Forest, Idaho Panhandle National Forest and Bitterroot National Forest. I’ve dedicated my career to natural resource management and understand how valuable these roadless areas are for wildlife populations. I strongly oppose removing the 2001 roadless area conservation rule. If this rule is removed this will affect Grizzly Bears, Salmon, Scrub jays and countless other species who depend on these intact habitats for survival.

One of my favorite places in the state of Montana is the Bitterroot National Forest, largely due to the miles of pristine trails that meander along the mountain tops and beside creeks winding through the many verdant valleys. In the winter, some of these trails can also be used for cross-country skiing, which is an exceedingly popular activity in the Bitterroot Valley and beyond. The National Forest also provides superb backcountry hunting and fishing opportunities that draw visitors from all over the state and beyond for our abundance of elk, deer, and trout. These miles of trails and forest have for years been protected by the Roadless Rule, which safeguards not only the health of wildlife and the environment in undisturbed areas of the country but human health and recreation. A rollback of the Roadless Rule would fragment intact ecosystems, harm wildlife, and increase wildfire risk by bringing in more human disturbance to 18.5 million acres of the Greater Yellowstone Area of Montana, Idaho, and Wyoming alone. According to the National Parks Service, 85% of wildfires in the US are caused by human activity, and introducing more industrialization to these vulnerable areas will only dangerously exacerbate the fire problems we in the western half of the US are already facing. In addition, a repeal would have massive implications for all backcountry recreation and consequently the tourism industry that helps keep rural communities like mine alive. Repealing the Roadless Rule would end protections for 8,659 climbing routes, 768 miles of whitewater paddling, and 25,121 miles of trails across the country, effectively destroying recreational opportunities for millions of people across the country, including myself and my colleagues who are also avid backpackers, hikers, skiers, and rock climbers. Many areas protected by the Roadless Rule also cover vital watershed areas that serve as a home for native species of trout and salmon, both fish that drive a great deal of our local tourism economy, which is dependent on seasonal fly-fishing. The impacts of erosion and pollution from logging and road-building in these areas would be disastrous for these aquatic populations and could drive communities built upon fishing tourism to economic ruin. Finally, habitat fragmentation and wildlife disruption would severely disturb populations of elk that inhabit the National Forest and the neighboring Selway-Bitterroot Wilderness. If these roadless areas of the forest are disturbed, thousands of outdoorsmen would lose a priceless ungulate hunting ground, which once again would have dire consequences for the seasonal tourism industry in my community and in neighboring areas. There is no logical reason to repeal a policy that is so effective in balancing active forest management, conservation, recreational opportunities and rural development. There is nothing to be gained by introducing industrial activities to these areas that would outweigh the irreparable losses to the natural beauty, tranquility, and wellness of our irreplaceable land. Our public lands have widely been regarded as “America’s best idea,” and protecting our natural resources is integral to the identity and cultural of the western US, particularly in the “Last Best Place” of Montana. Due to these factors, I implore you to stop the rescission of the Roadless Rule that has served our lands and our people so well for so long.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I hunt. What it would mean to me if this country got roaded: "I've hunted for 64 years. Hunting is our food, our way of life." The water I fish, in my own words: "I fish high mountain lakes, valley rivers and valley lakes." I hike the Selway Bitterroot Wilderness, the Sapphire roadless areas, the Pioneer Roadless areas, and the Anaconda Pintler Wilderness areas. The only time I truly feel free is when I'm on those lands. I watch Elk, Deer, Moose, bears, Turkeys as well as all the species of birds that use my forested lands. Water is the life blood of my valley, and it's under attack from outside mining interests. On what my kids should inherit out there: "These forest are my children and grandchildren's heritage. One I'll fight for." Fires are a natural part of our forests, I've seen this all my 65 years. It's necessary and part of the environment. I've commented on before and though I'm tired of the people that are trying to take away these lands, I'll fight until the day I day for them. These lands in question should be managed for clean water, wildlife, and human recreational purposes. The country I am writing about includes the Bitterroot National Forest. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Elk survival, in the agency’s own citation I hunt elk, and the security of unroaded country is what puts them there. The agency's own citation measured what roads cost them: 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. No population-level effect on big game is projected anywhere in the document. I ask that the agency project the effects on big game populations and hunter opportunity. Issue 2: Fragmentation is quantified and not applied I hunt deer, and what I need from this country is that it holds together. The agency put a number on fragmentation and then never applied it: The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. Issue 3: Reliance interests are invited and never assessed I have built years of hunting around the protection this rule provides. That is a reliance interest, and it is exactly what the agency invited comment on. The proposal solicits “any reliance interests in the current rule that could be affected by this proposal” (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Issue 4: Road sediment is quantified and then set aside I fish these waters, and clean gravel and clear current are what make them fishable. What roads send downstream lands on the fish first, and on me right after. The DEIS: skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and “can contribute up to 90 percent of the sediment generated by timber sale activity.” The number appears in the document; no projection of sediment delivery follows it. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. 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. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Robert S. Wood Hamilton, Mt 59840

Rescinding the Roadless Rule would be a net loss for outdoor enthusiasts so I am writing in hopes of being one of many voices urging our elected officials to keep the Roadless Rule in place. I've spent hundreds of days hunting, fishing and exploring areas within the roadless rule across multiple national forests, the bitterroot national forest (46.5577, -114.1988), the beaverhead (45.6573, -113.1540), the salmon (44.5787, -113.7441), this list could go on and on across numerous states. Countless memories, friendships and life long bonds of mine were created in these places. Please listen to the public and keep the roadless rule intact.

Hello, I am a concerned citizen who wants to speak up in favor of keeping the Roadless Rule. I am an active person who loves to be outside, and spent 2 summers working for the USFS on the Bitterroot National Forest. I explored so much of that land, and I want to see it protected. I am worried about the many endangered species who live in this area where you are proposing to put in new roads. They will lose vital habitat. Additionally, it could push more big predators into populated areas where they could have more human-wildlife interactions. The Roadless Rule protects wildlife, humans, and allows us all space to recreate, fish, hunt, and more! Projects can still be done. I have also worked on a trail crew in wilderness areas, and I know how satisfying it is to backpack in to a place without roads to work on a conservation or fuels project. I do not believe that building roads through pristine landscapes will be beneficial to people or the earth.