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Re: Docket No. FS-2025-0001 (RIN 0596-AD66) — Public Comment in Opposition to the Rescission / Amendment of the 2001 Roadless Area Conservation Rule To: Director, Ecosystem Management Coordination U.S. Department of Agriculture, Forest Service 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 I. Introduction I am writing to express my strong opposition to the proposed rescission and amendment of the 2001 Roadless Area Conservation Rule (Docket No. FS-2025-0001). As a resident and advocate for Teton County, Wyoming, I am deeply concerned about the potential impacts of opening Inventoried Roadless Areas (IRAs) within the Bridger-Teton National Forest to road construction, timber harvesting, and commercial development. The roadless landscapes surrounding Teton County represent an irreplaceable resource. Removing federal roadless protections in favor of localized discretion risks permanent damage to our ecological health, local economy, and public resources. II. Critical Wildlife Habitat and Ecosystem Integrity The Inventoried Roadless Areas in Teton County serve as vital sanctuaries for western wildlife within the Greater Yellowstone Ecosystem. Habitat Connectivity: These remote tracts provide core, contiguous habitat and critical movement corridors for species including grizzly bears, gray wolves, elk, moose, and bighorn sheep. Fragmentation Threats: Road construction and commercial logging break up contiguous forest canopy, introduce edge effects, create disturbance corridors, and encourage human-wildlife conflicts that degrade ecosystem resilience. III. Watershed Enhancement and Water Quality Protection The forests of Teton County are key headwaters for the Snake River Basin, providing critical ecological functions: Drinking Water & Quality: Roadless areas function as natural filtration systems, keeping sediment levels low and providing pristine drinking water for local communities downstream. Aquatic Habitat: Native cold-water fish, such as Snake River fine-spotted cutthroat trout, rely on clean, cold, and silt-free water. Industrial activity and road building increase soil erosion and sedimentation, threatening critical fish habitat. IV. Unsuitability for Commercial Logging Commercial timber extraction in the roadless areas of Teton County is ecologically unsustainable and economically inefficient: Steep Terrain & Soil Vulnerability: Much of the roadless terrain in the region is characterized by high elevation, steep slopes, and highly erodible soils, making road construction physically destructive and unstable. Low Timber Value: These slow-growing, high-altitude forests lack the commercial timber yields necessary to justify the immense public expenditure required to build and maintain access roads. Deferred Maintenance Deficit: Expanding road networks in remote areas creates long-term financial liabilities for the Forest Service, which already faces significant maintenance backlogs on existing national forest roads. V. Conclusion and Recommendation Rescinding or weakening the 2001 Roadless Area Conservation Rule threatens the water quality, wildlife habitat, and natural heritage of Teton County, Wyoming. The current national protections ensure that these high-value roadless lands remain intact for future generations. I respectfully request that the U.S. Department of Agriculture and the Forest Service withdraw the proposed rule change and maintain full protections under the 2001 Roadless Area Conservation Rule for all Inventoried Roadless Areas in Teton County and nationwide. Thank you for the opportunity to comment on this critical proposed action. Sincerely, David G Brown

Secretary Brooke Rollins U.S. Department of Agriculture 1400 Independence Ave. SW Washington, DC 20250 Thomas Schultz, Chief U.S. Forest Service 201 14th Street SW Washington, DC 20250 Re: Docket No. FS-2025-0001: Opposition to Rescission of the 2001 Roadless Area Conservation Rule and Comments on the Draft Environmental Impact Statement Dear Secretary Rollins and Chief Schultz: I urge USDA to retain the 2001 Roadless Area Conservation Rule, select the No Action Alternative, and revise the Draft Environmental Impact Statement (DEIS) as described below. I spend time in the Bridger-Teton National Forest near Jackson, Wyoming, most recently this September, including the Inventoried Roadless Areas along the Gros Ventre River east of town. I hike there and watch for elk, moose and other wildlife. What stays with me is how quickly the land beyond the Gros Ventre Road opens into quiet, unbroken forest and ridgeline, a short drive from a busy valley. Places like this provide clean water, wildlife habitat, recreation, solitude and some of the last intact forest in the country, and they stay that way only because no roads cut through them. The Rule already permits substantial forest management, including prescribed fire and hazardous fuels reduction. USDA argues that rescission would lower wildfire risk, yet the DEIS cites research finding that the absence of roads has not impeded fire prevention or protection work. The DEIS also acknowledges that nearly 90 percent of wildfires are human caused and that fires are more than four times as likely to start near a road. New roads would add ignition sources, not remove them. If specific constraints on fuels work exist, USDA should identify and address them directly rather than remove protections nationwide. The DEIS does not adequately assess the reasonably foreseeable national and regional effects of removing protections from 44.7 million acres of public land. Deferring NEPA review to future site-specific projects cannot fill that gap. Project-level reviews will not capture cumulative effects on landscape fragmentation, habitat connectivity, native plant communities, invasive species, interstate and cross-forest migration corridors, or regional watersheds. In the Greater Yellowstone Ecosystem, where elk, pronghorn and other wildlife move across multiple forests and state lines, those cumulative effects are the whole question. USDA should analyze now where rescission would most endanger intact habitat, wildlife movement and native plants, and where new roads and logging would most threaten watersheds and drinking water supplies. Rescission would also remove protections from 9.3 million acres of the Tongass National Forest. USDA relies on the 2020 Alaska Roadless Rule Final EIS but has not shown that this earlier analysis adequately evaluates rescission. Tribal consultation is also incomplete. USDA should fully weigh Tribal concerns about subsistence, cultural resources, fish and wildlife, and intact landscapes before reaching a final decision. I urge you to keep the Rule's national protections in place and to analyze the reasonably foreseeable effects of rescission now, before any final decision. Sincerely, Ryan McMorrow

Director, Ecosystem Management Coordination 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 8 September 2026 Dear Director, The Wyoming Native Plant Society is writing to address the proposed rescinding of the Roadless Rule (90 FR 42179) as posted on 20 August 2026. These comments underscore and update those we submitted on 25 Sept 2025 in response to the initial announcement. It is apparent to our members that this proposed action would promote activities and development that have been historically associated with undermining ecological functions of intact landscapes, threatening whole ecosystems and specific habitats for sensitive and/or threatened plant and animal species and their capacity to contribute to healthy air, soil and water qualities in Wyoming and throughout the western United States. We also maintain that this proposal is not consistent with the stated goal of improving forest management as implied by an act of rescission. Instead, it is proposes rolling back standards, promoting development work detrimental to healthy landscapes. It is based on flawed arguments: roads and logging don’t prevent wildfire but are frequent contributing factors. This is supported by the following facts: Over 7% of the total roadless area is in Wyoming. In 2022, we experienced the biggest fire event in state history, the Mullen Fire, as started by human cause, virtually all outside of roadless inventory area (spanning a number of timber sales). In 2024, Wyoming had the biggest fire year since the Yellowstone Fires that was started by lightning strikes and which burned more acres of private property below the mountains than in roadless inventoried areas of the Bighorn National Forest (3 converging rangeland fires and the Elk Fire, respectively). By contrast, in 2025, with an exceptionally early start to wildfire season, a lightning strike ignited on June 13 in a roadless inventory area of the Bridger-Teton National Forest (Horse Creek Fire) only burned a limited area thanks to the time of year and considerable fire-fighting effort. Wyoming needs its own plan to address Roadless Inventoried lands that span greater than 33% of the 9.2 million acres (about 14,375 mi²) of national forest in our state. Many of Wyoming’s roadless areas represent the “Wildland-Urban Interface” as cases of urban sprawl and accompanying local development pressure. Turning over national decision-making to individual forests jeopardizes the entire process of “giving due consideration to the relative values of the various resources in particular areas” by national standards. A Wyoming plan is also needed to address unique Wyoming conditions as with the mining areas that boomed 150 years ago, creating a multitude of primitive roads which later became national forest in the Shoshone National Forest. Finally, a Wyoming plan is needed to address the many roadless areas that are critical in maintaining designated wilderness landscape intactness. Any change to the current rule has heightened needs for fair and consistent public communication and management planning on the part of the U.S. Forest Service. However, the U.S. Forest Service at the level of each of the eight national forests in Wyoming is least able to address these needs in general or the complexity of coordinating at the wildland-urban interface at any point in its recent history in light of these 2025-26 events: •mass firings in the U.S. Forest Service starting in February 2025, and •massive reorganization of the U.S. Forest Serivce underway (https://www.fs.usda.gov/about-agency/reorganization) as eliminating a regional level of coordination and transferring regional responsibilities to each national forest, while also creating a new level of state offices in locations with virtually no U.S. Forest Service presence. These events created unprecedented turmoil for personnel at all levels of work making it impossible for the Forest Service to fairly implement this proposed action. A recent paper posted by the University of Wyoming (Aragon 2025) presents an interpretation that the risks of the proposed action may exceed the benefits (https://www.uwyo.edu/law/centers/center-for-land-and-water-law/blog/long-road-rescinding-roadless-rule.html ). Any action on the Roadless Rule should be put on hold or only considered insofar as States demonstrate the capacity for addressing plans that in turn, are approved by Congress. Sincerely, Lyle King, Conservation Committee Wyoming Native Plant Society