Read the comments.

The proposal to rescind the 2001 Roadless Area Conservation Rule is a nonsensical maneuver by the USDA purely to pander to extractive interests (timber, mineral, oil, etc.). I argue against rescinding the Roadless Area Conservation Rule for two reasons: this is exemplary of the USDA's inability to understand delayed gratification and an existing inability to manage lands that are already not covered by the roadless rule, thereby stretching an already strained department even farther beyond its limits. The proposal purports to be disconnected from the list of executive orders associated with timber production (EX 14192, 14225, 14154, and 14153, see, Purpose and Need for Action). However, the average educated reader easily understands that the purpose of "reduc[ing] regulatory burden and return[ing] decisionmaking [sic]...to the land management planning process at the individual national forest level" (Summary) is to make it easier for extractive industries to access the lands that form the backbone of our national treasure, the National Forests. The National Forests are remarkable in the width, breadth, access, and availability as a multi-use space. Already timber interests have regular access to the forests, and those of us used to living in small towns across the mountains of the American West have plenty of experience in running into a fully loaded logging truck on a narrow road or encountering the unpleasant results of timber harvesting in our backyards. From the perspective of a small town American, more of this is not necessary. Or, as they say: Not In My Backyard. Logging trucks are loud, they destroy existing roads, they endanger other users simply by being too big and too much in a hurry. If protection is not granted at the federal level, how can the Forest Service--dramatically understaffed--in my parents' small, rural town in the Pacific Northwest, assess the environmental cost of road-building to support economically and politically powerful timber interests? How can an effective land management plan that supports all interests successfully be constructed? David beats Goliath, but only because David has a sling. If the sling of the Roadless Rule is gutted, how can small towns and local businesses survive against mass industry that trucks all the trees out of town to be processed elsewhere? How is that representing the local American? Second, the proposal to rescind suggests that rescinding the Roadless Rule will somehow improve our wildfire response. This is, of course, absolute nonsense. Simply put: the current resources available to fight fire cannot manage fire in areas that already have roads, much less to protect areas far beyond human habitation. As an example: some years ago, the Forest Service performed hazardous fuel mitigation in the Carson National Forest near Pot Creek, NM where my extended family lives. Substantial thinning took place, but there was no subsequent removal or remediation of the thinned material. Instead, the cut material was left in piles scattered throughout the area to get drier and more hazardous in the fire season. In the same area, the USFS lost control of a controlled burn, which threatened lives and houses. It seems clear to me that the USFS is struggling to manage areas with existing roads, and opening roadless areas to road-building is unlikely to improve departmental performance. The USDA would do better to focus on increased resources (more money, more employees, less bureaucratic nonsense) for the USFS in order to actually protect the lives of Americans and to keep our great national forests healthy so that everyone can use them.

Roadless forest keeps the natural habitat intact, I remember driving through Carson national forest in NM, and saw how a highway or even a forest road would cut the landscape, divide the habitat. Roads require maintenance, weed control, and other invasive methods to keep it from getting reclaimed. Roads also cause unnecessary flooding and runoff, and introduction of foreign material into the pristine waters and soils of national forests. Most fires are started close to roads. So there is an increased risk of wildfire as well. I am therefore against the roads in the forests.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The backcountry is where I harvest food for my family, teach my children the skills they need, and remind them that the natural world exists beyond screens. Bikepacking has shown me how far roadless country extends and how quickly a road can shrink it. The Pecos area in Carson National Forest, New Mexico, is a gem, and something that needs to be preserved for future generations. 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. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres. The Pecos alone accounts for 13,436 of them. When I take my children into that country and go off trail to find food, I am depending on the character that roadless designation protects. The agency's own record acknowledges that 739 municipal water intakes across the Southwestern region sit in watersheds containing affected roadless areas. The proposal does not adequately account for what road construction would do to the water those communities and that country depend on, and I expect the agency to address that gap directly. The wildfire rationale offered for rescission is the one I find hardest to square with what the agency itself has written. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That is the agency's own language, cited in support of the protection this rule provides. The proposal now treats road access as a tool for reducing fire risk, but the agency's prior findings point in the opposite direction. I ask that the agency explain why the current proposal departs from those findings and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case is similarly difficult to follow. The agency's record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that baseline, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, set against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The Forest Service is already carrying a $6.9 billion road maintenance backlog. How does an action whose own analysis cannot establish a net benefit justify expanding a road system that already cannot be maintained? The agency must answer that question with specificity before this proposal moves forward. When I hunt off trail, the quality of the habitat determines everything. The agency's record is candid about what roads do to the animals I pursue: "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." That finding is in the record. What is not in the record is any projection of what rescission would mean for elk populations or for the hunter opportunity that depends on them. The agency should provide that projection before reaching a final decision. The fragmentation data present the same problem at a larger scale. The agency's record states: "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is cited and then left suspended. No projection applies it to the 40.1 million acres of potentially affected environment. A cited finding that spans 13 to 75 percent is not a minor uncertainty. The agency must apply that range to the full extent of the affected environment and show what it means in practice, not simply note the number and move on. The Pecos is the kind of place that does not come back once it is roaded. I ask the agency to respond to each of the deficiencies identified here before finalizing any action that would rescind the protections the 2001 rule provides. Sincerely, Jesse Woosley Santa Fe, NM

Our National Forests provide clean drinking water, habitat for fish and wildlife, beautiful places to hike and camp, and some of our nation’s last stands of old growth forest. My community knows this firsthand because we’re lucky enough to live near Carson National Forest. Right now, the Forest Service is trying to roll back protections for some of our best and last remaining forested areas by getting rid of the “Roadless Rule”. This Rule, created in 2001, restricted expensive roadbuilding in these last refuges for water and wildlife. Is this what we need now – fewer protected forest areas? The Forest Service already manages a road system that is over seven times larger than the Interstate Highway System! Should taxpayers be on the hook to build more expensive roads that damage our water, wildlife, and outdoors? The Forest Service and our elected officials need to hear that building more roads is the wrong direction, and trying to sneak this massive rule change through without public meetings is cowardly and wrong. This summer was extremely dry in the Southwest and many animals have been suffering, especially the bears. We have already encroached enough into their habitat. We do not need more access. We need to maintain the road access that is already in place. Just because a rapist wants to rape our forest resources doesn't mean you men in power should let him. It makes you complicit in the rape. I do not support ending the roadless rule. And neither should you.

To the Forest Service: I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR part 294, subpart B). I haven been an avid hike for almost 20 years, hiking several times a week (or more). This includes national parks and national forests including the following: • Angeles National Forest • Arapaho National Forest • Carson National Forest • Cleveland National Forest • Inyo National Forest • Lassen National Forest • Pike National Forest • Rio Grande National Forest • Roosevelt National Forest • Routt National Forest • San Bernardino National Forest • White River National Forest Hiking is important to both my physical and mental health and has played an important role in my volunteer work to help veterans reintegrate following their service and find community. Taking them on hikes has been a powerful way to bolster their health and wellness. The 2001 Rule protects roughly 58.5 million acres of inventoried roadless areas by generally prohibiting road construction, road reconstruction, and timber harvesting, with limited exceptions. Rescinding it removes that protection nationwide. The notice states that the rescission does not itself mandate timber cutting or road building. But it removes the rule that currently prevents them, and the agency should be candid that this makes road construction and logging in these areas possible where they are now generally prohibited. For hikers, the value of these areas is that they are undeveloped. A trail through a roadless area offers quiet, solitude, and a sense of remoteness that cannot be rebuilt once a road is cut through. Opening the door to new roads and logging puts those experiences at risk, and the loss would be permanent in a way that is very hard to undo. The Department's stated reasons for the proposal are to reduce regulatory burden and to return decisions to local Forest Service officials. I ask the agency to address the following in the final rule and EIS: How will recreation be weighed? If decisions move to the local level, what required standard will ensure that the value of undeveloped backcountry for hiking and other dispersed recreation is considered, rather than left to discretion project by project? What is the burden being relieved? Please identify the specific, documented costs of the 2001 Rule, and show that they outweigh the benefits of keeping a consistent nationwide protection. Why rescind rather than amend? If there are specific problems with the rule, why does the Department propose eliminating it entirely instead of a narrower fix? How will the public be involved? Under the proposal, how would hikers and other recreation users learn of and comment on future decisions affecting individual roadless areas? I also ask that the Department give the public adequate time to review a proposal of this size. The rescission was issued alongside a draft environmental impact statement and a cost-benefit analysis, with an original 30-day comment period. I urge the Department to withdraw the proposed rescission and keep the 2001 Roadless Area Conservation Rule in place. Sincerely, Laura W. Fort Collins, CO

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Roadless Area Conservation Rule has protected places that matter to real people doing real work, and rescinding it would be a mistake this country will spend decades undoing. I worked for the Forest Service at Carson National Forest and saw firsthand how valuable roadless areas are to both the people and the businesses around them. The roadless areas near Sipapu Ski Resort meant available clean water, less fire risk, and they did not prevent the continued expansion of the resort. Visitors, residents, and snow-making operations all depended on that water. Having lived in northern New Mexico, I know that water is scarce and hard-won. Entire towns understand that without the water quality protection roadless areas provide, the town itself is at risk. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres, and across the Southwestern region 739 municipal water intakes sit in watersheds containing affected roadless areas. The stakes for communities here are not abstract. On wildfire, I have watched what roads actually do. I've had to leave many areas due to roadside fires started. I was also living in Taos when the Calf Canyon Fire started, and I returned to work on Carson National Forest right after it. While that fire started from a different cause, what I witnessed was a difficult recovery paired with hard discussions about past Forest Service mismanagement that increased fire risk. One thing became clear in those conversations about past local fires: roads increase fire risk because they increase human activity. The agency's own record states, "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The current rule already allows roads for firefighting. Repealing it and permitting additional traffic and logging will increase ignition risk to the communities nearby. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The financial case for rescission does not hold together either. There is already a shortage of funds to manage existing roads. Creating new ones is a mismanagement of funds, and it makes zero sense financially, safety-wise, or as a long-term investment in the economy and health of these forests. The agency's own record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency must reconcile this proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and it must explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The agency also has not explained what specific permitting or administrative burdens the rule actually creates that cannot already be addressed under its own exceptions. The rule as written "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency should identify which specific burdens are not already addressed by existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and it should quantify those burdens on the record rather than assert them. Finally, this comment is itself a reliance interest. My work on Carson National Forest, my understanding of what these areas protect, and the communities I have seen depend on clean water and reduced fire risk all rest on the continued operation of the rule. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. The agency must identify and genuinely weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further. Keep the rule in place and keep protecting the people nearby. Sincerely, A concerned citizen

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The children I work with in my forest school program are under eight years old. What I bring them to, every time, is the national forest near where I live. Birds, deer, fox, coyotes: these are not abstractions for them. They are the lesson. When this administration proposes to rescind the 2001 Roadless Area Conservation Rule entirely, it is proposing to dismantle the protection that makes that lesson possible. I have backpacked in the Pecos, in the Carson National Forest, for over a decade and a half. Losing that would be painful. That is the only word I have for it, and I think it is the right one. Rio Medio, in the Santa Fe National Forest, is so incredibly special, and losing it would impact the watershed. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres. These are not marginal scraps. They are the water supply and the wildlife corridor and the quiet that makes birds findable and children teachable. On fire, the agency's own record undermines its own justification. The DEIS states directly: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal cites fuels management as a rationale for rescission. Those two positions cannot both be true. I ask the agency to explain the departure from its own prior findings and to reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The birds I look for with children in these forests depend on exactly the conditions the rule protects. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. For deer, the agency's own record cites research finding that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed, and the Tribal Summary Impact Statement credits the rule's protection with deer population recovery by preserving old-growth winter shelter. These are not outside critiques. These are the agency's own citations. I want to know how the agency squares opening these areas to roads with its own documented findings on the wildlife consequences of doing so. The economic case for rescission does not hold up either. The record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million. Across the Southwestern region alone, which includes New Mexico, 739 municipal water intakes sit in watersheds containing affected roadless areas. The agency must reconcile this proposal with an analysis that cannot establish a net benefit, and explain how it justifies expanding a road system already carrying a $6.9 billion maintenance backlog. On the state-by-state approach the proposal advances: the record itself records the agency's prior rejection of the rule's approach in favor of local flexibility, citing "its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That approach was litigated and lost. The agency must address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and explain how this proposal avoids the deficiencies identified the last time the national rule was replaced with a state-by-state system. Finally, on statutory authority: the Tenth Circuit already reviewed that question and held that the 2001 rule was within the authority Congress granted. The court stated: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address that holding, including the court's conclusions regarding the Organic Act and the Multiple-Use Sustained-Yield Act, and explain the basis for any contrary legal position. I oppose this rescission. The places it would open are the places I work in and love. The agency's own record does not support this action. Sincerely, Resident of Santa Fe, NM

I urge the Forest Service to retain the Roadless Area Conservation Rule in its entirety and oppose any proposal to rescind or weaken its protections. My concerns are wildlife and access driven. I have seen roads in Carson National Forest go from being passable truck roads to jeep trails to side by side racing trails that are no longer accessible by truck. My thoughts are to keep motorized vehicles where they are currently limited to and allow timber harvesting in the same manner that fire suppression operates, create the road for the project and remove it when done under permit. Please do not allow utv’s and arc’s to destroy our trail system. This is already happening in places that the forest service does not monitor or enforce regulations on a consistent basis.

Please do not repeal the Roadless rule. Natural spaces are essential for human reflection and recovery in challenging times. After my brothers death in 2016 (ski accident), I healed in part by hiking through areas of the Carson National Forest in New Mexico. The opportunity to escape the sounds of motors and machinery, to only hear the winds through whispering pines, was critical for my emotional recovery after my family's tragedy. Hiking and backpacking in other National Forest land in Utah, California, Colorado, Arizona, and Montana have similarly been important of my mental health, personal growth, and religious expression. Please continue protecting wilderness spaces by keeping the Roadless rule in place.

Forests do not stop at state lines. While Colorado's 4.4 million acres of roadless areas are exempt from this move, the state can still amend protections for temporary roads, as done in 2017 with the North Fork Coal Mining Area. Colorado national forests connect critical habitat with other pristine landscapes on three of its borders. This includes the Rio Grande National Forest, with roadless areas acting as "stepping stones" from the Carson National Forest in New Mexico. Most of these connected forests sit along the northern border into Wyoming. Both of these connect to the Continental Divide National Scenic Trail (CDT).

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Chama River and the Pecos roadless country in Carson National Forest are wild and timeless, and that quality is precisely what this rescission would put at risk. I paddle the Chama and I watch migrating songbirds, and the roadless character of the landscapes surrounding that water and those forests is not incidental to what I find there. It is the thing itself. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres. The Pecos roadless area in Carson National Forest covers 13,436 of those acres. The birds I go looking for, all the migrating songbirds moving through forested habitat, depend on exactly the conditions that roadless designation protects. The agency's own draft environmental impact statement cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. I watch those birds in places like the Pecos country because the roads are not there. The agency must explain what its analysis concludes about bird abundance and species presence in the Pecos roadless area specifically if new road access is permitted, and it must answer that question in the record before any final action. The proposal justifies rescission in part on wildfire and fuels management grounds. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency cannot claim that opening roadless areas to road construction will reduce fire hazard while its own findings say the opposite. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement. That data is specific. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The gap between those two numbers is not marginal. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against whatever reduction in wildfire hazard the proposal claims to produce. Across the Southwestern region, which includes New Mexico, 739 municipal water intakes sit in watersheds containing affected roadless areas. I paddle the Chama and I understand what watershed integrity means to the water in that river. Road construction in roadless areas alters hydrology, increases sedimentation and degrades the watershed conditions that municipal and recreational users alike depend on. The agency has not demonstrated that the benefits of rescission outweigh those documented watershed risks, and I expect a response in the record on that point. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading losses across every small firm in the sector nationally rather than assessing the operators actually holding permits in the affected areas. The agency must withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. I have arranged my use of public land, including the Pecos country and the Chama watershed, around the expectation that the 2001 rule would remain in place. That reliance is real. An agency changing course is obligated to identify and weigh the reliance interests its prior policy created. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Sarah Bensinger Los Angeles resident and (New Mexico frequent visitor)

Roadless areas are very important for a number of reasons, but I will focus on the negative effects of vehicle traffic for hunting. For me personally, nothing ruins an outdoor experience more than hearing or seeing vehicles out in the woods. Just two weeks ago while elk hunting in the Carson National Forest in New Mexico I witnessed significant abuse of roadless areas well off of an already closed road. I watched three men drive their truck way off the road up a drainage so they did not have to pack an elk out. They drove through many wetlands and crossed a stream several times, leaving ruts and other damage. It was very lazy. The more roads we have, the more of the remaining wild country will be abused by people who have no respect for anything or anyone.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Thirty years of camping and hiking in the Pecos Wilderness have given my family something we do not want to lose. We go there because it is remote and wild. In the high country and along the Pecos River we look for elk, deer, and bighorn sheep, for red-tailed hawks, songbirds, and Steller's, Piñon, and Scrub jays. My kids grew up in that place and they want to return to it with their own families. The Pecos inventoried roadless area in the Carson National Forest and El Invierno in the Santa Fe National Forest are part of what makes that possible. The proposal to rescind the 2001 Roadless Area Conservation Rule threatens both, and I oppose it. The agency has justified this rescission in part on wildfire and fuels management grounds, but its own record contradicts that justification directly. 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." We have already seen fire damage in the Pecos Wilderness and we do not want to see more damage from man-made causes. Roads bring more ignitions, and the agency's own draft environmental impact statement confirms it. I ask that the agency reconcile this proposal with DEIS Table 21, which reports far higher fire density on roaded land than inside affected roadless areas, and explain in the record why its stated justification departs from its own prior findings. The economic case for rescission is just as weak. The agency's record shows that the timber volume affected by this rule is less than 0.5 percent of total United States production and that oil and gas production from all National Forest System lands is about 0.4 percent of national production. Against that, the agency's own cost-benefit analysis projects timber revenue of $5.2 to $11.4 million a year to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. The agency cannot even establish a net benefit in its own analysis, yet it proposes to expand a road system already carrying a $6.9 billion maintenance backlog. I ask that the agency explain how an action whose own numbers fail to confirm a net gain justifies that expansion. My family looks for elk and deer throughout the forest and in the riparian corridors near the Pecos River. The agency's own citations show that elk avoid areas near roads and select unroaded habitat with cover and forage, and that elk survival rates rose during a road closure and fell again when the gates were removed. The DEIS cites research finding that roads built for extraction may have altered mule deer migration routes and increased their movement speed. Commenters specifically asked the agency to protect big game habitat, fisheries, and wildlife connectivity, and Alternative 3 was built to address those concerns. The agency then chose the alternative that protects none of it. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres, and 739 municipal water intakes in the Southwestern region sit in watersheds containing affected roadless areas. Clean water is a finite resource, and the agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I want the agency to state clearly in the record why it chose an alternative that abandons the wildlife and watershed protections commenters specifically requested. The proposal also argues that state-by-state approaches can substitute for a national rule. But the agency's own record quotes its prior position that the Roadless Rule reflected an "inflexible 'one-size-fits-all' nationwide rulemaking approach," and a court has already evaluated what happens when the agency acts on that view. The Tenth Circuit, exercising jurisdiction under 28 U.S.C. Section 1291, reversed and remanded the district court's permanent injunction and held that the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA. The agency must explain how this proposal avoids the deficiencies that doomed the previous state-by-state replacement, and address the Tenth Circuit's holding that the rule did not create de facto wilderness. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the 2001 rule. It has held none to undo it. My family has been part of this place for over 30 years. The old-growth spruce, fir, and aspen in the Pecos Wilderness exist because some lands were kept from roads and development. That is not an accident. It is a policy choice, and this administration should not reverse it without answering the questions its own record raises. Sincerely, Susan Schauer White Rock, NM

Dear Chief and Staff of the U.S. Forest Service, ​I am writing to express my strong opposition to the U.S. Department of Agriculture’s proposal to rescind the 2001 Roadless Area Conservation Rule. As someone whose deep appreciation for public lands spans a lifetime, I strongly urge the agency to maintain full protections for our remaining 44.7 million acres of Inventoried Roadless Areas (IRAs). ​My love for public lands is personal and lifelong. Growing up near the Carson National Forest in New Mexico, I experienced firsthand the sanctuary, beauty, and ecological importance of intact, roadless forest lands. Today, my family and I have set a goal to visit all 63 of America’s National Parks. We have already explored every National Park across California, Oregon, Washington, Nevada, and Utah. Through these journeys, my children, are learning to love, respect, and appreciate the great outdoors. Protecting wild lands is essential not just for the quality of life we enjoy today, but so these extraordinary places remain whole for my daughters and generations to come. ​Rescinding national roadless protections in favor of localized, fragmented decision-making poses severe threats to our public lands: ​Loss of Natural Beauty and Recreation Values: Opening intact forests to road construction, industrial timber harvesting, and resource extraction permanently degrades scenic viewsheds, pollutes headwaters, and disrupts pristine landscapes that draw millions of outdoor enthusiasts annually. ​Impacts on Biodiversity: Roadless areas provide vital, unfragmented habitat corridors for fish and wildlife. Constructing new roads fragments critical range, exposes wildlife to human disturbance, and increases the introduction of invasive species. ​Threats to Adjacent National Parks: Our National Forests and National Parks do not exist in isolation; they share watershed boundaries, ecosystems, and migratory pathways. Industrial development and road-building on the boundaries of wild forest lands directly threaten and undermine the integrity of neighboring national parks. ​Existing Management Flexibility: The existing 2001 Roadless Rule already contains explicit exceptions for firefighter safety, public safety, and critical hazardous fuels reduction to manage wildfire risks. A total rescission is an unnecessary step that prioritizes commercial exploitation over long-term stewardship. ​Once a road is cut through an intact forest ecosystem, the ecological damage is irreversible. We owe it to our children and future generations of Americans to keep these wild areas road-free, resilient, and intact. ​I respectfully request that the Forest Service withdraw the proposed rescission and uphold the 2001 Roadless Rule in full.

I am a citizen of New Mexico and I am writing to strongly oppose rescission of the Roadless Rule. The Roadless Rule is twenty-five years old and was established after 600 public meetings and 1.6 million comments by the public. The establishment of the Roadless Rule followed one of the broadest public engagement efforts ever by the US Forest Service, and that showed once and for all that there is outstanding positive support for protecting roadless forests. In New Mexico alone, there are 1.6 million acres of Inventoried Roadless Areas. It is important to me personally to keep New Mexico forest areas free of roads, logging and extractive industries. First of all, my family is fed by the venison, duck, elk and fish that my brother, a licensed hunter and fisherman, hunts and catches on roadless areas including in the Pecos Wilderness, the Lincoln National Forest and the Carson National Forest. Secondly, although I live in Albuquerque which is a metropolitan area of about a million people, for my mental health, I can quickly escape the city and hike or snowshoe in the nearby Cibola National Forest. I also hike and snowshoe in the Santa Fe National Forest; in fact, some of my most important memories of my mother, who died in 2025, are of us snowshoeing together in National Forest lands. I would be devastated if I were to return to those places and find them criss-crossed with roads. Thirdly, as a taxpayer, I am completely opposed to using my tax dollars to build new roads which then are more likely to increase forest fires—which also need to be fought using my tax dollars. A January 2026 scholarly article in journal Fire Ecology [full citation below*] concluded that: “The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha).” In plain English that means that fires are most likely to start within 50 meters of roads, not in roadless areas. So, please, don’t try to claim that the repeal of the Roadless Rule is to prevent or reduce wildfires—we, the public, know better! In summary, keep the Roadless Rule as is--it has served the voting public well for twenty-five years and there are no valid reasons to change it. * Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2

My family wants to continue hiking the trails of Carson National Forest and Santa Fe National Forest, and this proposed rescission of the 2001 Roadless Area Conservation Rule puts that future at serious risk. I oppose the proposal and ask the agency to address the specific concerns below before moving forward. New Mexico's water is a precious resource that must be protected at all costs. Roadless areas across the national forests feed the watersheds that communities depend on, and opening those lands to road construction and timber harvest introduces sediment, pathogens, and runoff that no set of management practices can fully prevent. The scale of exposure here is not abstract. As documented in Table 35 of the DEIS, "there are more than 7,000 municipal water intakes within watersheds containing potentially affected inventoried roadless areas." Despite that documented exposure, the water quality analysis in the DEIS is entirely qualitative and programmatic. There is no quantitative modeling of sediment loads, pathogen risk, or the treatment cost increases that road construction and timber harvest could generate. The document acknowledges that Best Management Practices reduce but do not eliminate impacts, which is not an adequate substitute for watershed-specific analysis. The agency must explain, on the record, how it can justify rescinding nationwide protections while leaving that analytical gap unfilled. I also do not want my taxes used to open up these protected lands to mining and logging operations that will hurt the ecosystem for decades to come. The DEIS frames projected increases in sawtimber harvest under alternatives 2 and 3 as a national benefit, but it does not honestly account for what that harvest pressure means when layered onto existing statutory obligations. As noted at Table 4 of the DEIS, the One Big Beautiful Bill Act "Directs the Forest Service to annually, beginning in FY2026 and through FY2034, sell a quantity of timber on National Forest System land that is at least 250 million board feet greater than the quantity that was sold in the previous fiscal year." That mandate applies to National Forest System lands regardless of this rulemaking. The DEIS lists that Act as a reasonably foreseeable action but never integrates it with IRA-specific harvest projections into a genuine cumulative effects analysis. The operability estimates the agency relies on to predict IRA harvest levels were not developed against a backdrop of a decade-long, escalating statutory volume mandate. The agency should prepare and release a cumulative effects analysis combining that statutory obligation with IRA-specific projections across all affected resource areas before this rule is finalized. The trails of Carson National Forest and Santa Fe National Forest represent something my family values and wants to pass on. The protections established in 2001 have kept those landscapes intact precisely because site-by-site, forest-by-forest decisionmaking lacked consistent standards. Returning to that approach, against a backdrop of escalating harvest mandates and unanalyzed water quality risks, is not a course of responsible management. The agency should answer each of the points raised above before it proceeds further with this proposal.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Pecos Wilderness and the Santa Fe National Forest are where I go for solitude and spiritual connection. I photograph landscapes in recovery, change over time, the slow work that intact ground does when it is left to heal. I want those places managed so they remain functional, intact ecosystems into the future. I am filing this comment to oppose rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I am asking the agency to answer specific questions that its own record raises. I lost my house in a wildfire that started on the national forest. That is not an abstraction for me. It is also why the agency's stated rationale for this rescission troubles me so deeply. The proposal leans on wildfire and fuels management as a justification for opening roadless areas to roads, but the agency's own record says the opposite. The agency has found that "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 am asking the agency to explain in this proceeding why the proposal departs from that finding, and to reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. I also helped with a roadless area inventory effort and saw firsthand how much erosion, trash, and damage come along with roads. That work gave me a ground-level understanding of what roads actually do to landscape. The areas I am writing through, Grace Tract at 999 acres and Maestas at 475 acres in the Santa Fe National Forest, and the Pecos roadless area at 13,436 acres in the Carson National Forest, are places I know through photography and on foot. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres. Across the Southwestern region, which includes New Mexico, 739 municipal water intakes sit in watersheds containing affected roadless areas. A road changes all of that, and the inventory work I participated in showed me exactly how. The economic case for rescission does not survive contact with the agency's own numbers. The 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." Against those figures, the agency's Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, against recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million. That range cannot establish a net benefit. The agency should explain on the record how a proposal whose own analysis cannot demonstrate positive returns justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The small-business certification in the supporting regulatory analysis reaches its no-impact conclusion by spreading a $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters, guides, and tour operators who actually hold permits in the affected areas. The proposed rule itself certifies no significant impact on small entities while the DEIS names outfitters, guides, and tour operators as affected, and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The agency should withdraw that certification and assess the impact on the small entities actually operating in these areas, not the national average firm. Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. I have organized parts of my work, my photography of landscapes in recovery, around the protections this rule provides. This comment is one of those reliance interests. The agency should identify and weigh what it finds in the record it receives, including this letter. Sincerely, Kathryn M Las Dispensas, NM

As a conservationist I am opposed to opening new/ old roads in our national forest. The harm that will be done is documented. We can manage the forests and fires without development. As someone who lives surrounded by the Carson national forest I am against opening roadless areas.

Dear Secretary Brooke L. Rollins: Writing as a citizen whose climate reading is sustained and whose engagement with federal land policy is a matter of attention rather than profession, I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule on the present record. I use this area for hiking and cold-water trout fishing. One visit made that connection concrete. My first time fly fishing in the Taos area was on Rio Hondo, which is fed by snowmelt and springs in the Wheeler Peak area. It is where I learned to trout fish in cold mountain water. The Department is not being asked to weigh an abstract preference; it is being asked to weigh a concrete, demonstrated interest of the kind the Rule was enacted to protect. Regarding the Wheeler Peak Wilderness in the Carson National Forest, New Mexico: Road construction generates more sediment per unit area than any other land use on national forest lands. The Wheeler Peak Wilderness IRA, Carson National Forest, has none of this sediment loading because it has no roads. Rescission of the Roadless Rule removes the regulatory barrier that prevents the introduction of the single most damaging non-point source pollutant into this watershed. The hydrological integrity of the Wheeler Peak Wilderness IRA, Carson National Forest, depends on the absence of roads. Road networks alter watershed hydrology at three scales: locally, by creating impervious surfaces and intercepting subsurface flow; at the reach scale, by delivering sediment at stream crossings and removing canopy; and cumulatively, by increasing peak flows and reducing baseflow across the drainage. All three scales of impact begin with the first mile of road. The DEIS must provide watershed-level analysis specific to the Wheeler Peak Wilderness IRA, Carson National Forest — not programmatic generalizations applied across all inventoried roadless areas. The geology, soils, slopes, precipitation, stream network, and downstream uses of this watershed are specific to this place, and the analysis must reflect that specificity. "Road construction increases soil compaction up to 200 times relative to undisturbed sites. Direct transfer of sediment and other material to streams and other water bodies at road crossings is an inevitable consequence of road construction. The surfaces of unpaved roads can route fine sediments to streams, lakes, and wetlands, increasing the turbidity of the waters. The consequences of past sediment delivery are long-lasting and cumulative, and cannot be effectively mitigated. Our review underscores the importance to conservation of avoiding construction of new roads in roadless or sparsely roaded areas." — Conservation Biology (Wiley), 2000 Road construction increases soil compaction up to 200 times relative to undisturbed sites. Direct transfer of sediment and other material to streams and other water bodies at road crossings is an inevitable consequence of road construction. The surfaces of unpaved roads can route fine sediments to streams, lakes, and wetlands, increasing the turbidity of the waters. The consequences of past sediment delivery are long-lasting and cumulative, and cannot be effectively mitigated. Our review underscores the importance to conservation of avoiding construction of new roads in roadless or sparsely roaded areas. — Conservation Biology (Wiley), 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x) A multi-taxon global freshwater fauna assessment for The IUCN Red List of Threatened Species covering 23,496 decapod crustaceans, fishes and odonates found that one-quarter (24%) are threatened with extinction. Prevalent threats include pollution, dams and water extraction, agriculture and invasive species, with overharvesting also driving extinctions. There are 89 confirmed and an additional 178 suspected extinctions since 1500. — Nature, 2025 (https://doi.org/10.1038/s41586-024-08375-z) Twenty-five years of implementation, repeated judicial affirmation, and the absence of a reasoned basis for change all counsel against rescission; the Rule should be maintained. Thank you, Scott Walker, ScEdD