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I am writing concerning the proposal to rescind the Roadless Rule that is currently protecting 45 million acres in our National Forests. I am absolutely opposed to rescinding the Roadless Rule. I am 100% in favor of KEEPING the Roadless Rule in place. The roadless rule protects our old growth forests and sensitive ecosystems. It PREVENTS forest fires, and it PROTECTS our watersheds, which support wildlife and provide us with safe drinking water. I reside in Florida, and I love our Public lands. I have visited, camped and hiked in many of our national forests inlcuding Pisgah National Forest, The Great Smoky Mountains, Grand Targhee, Cibola National Forest, Lolo National Forest, Gulf Islands National Seashore, Bristlecone Pine Forest and more. I live part time in New Hampshire, where I enjoy hiking in the White Mountains. I am aware of the Granite State’s significance in establishing a National Forest service to begin with. Over 100 years ago, logging led to widespread wildfires and deforestation which in turn caused erosion and landslides which resulted in massive pollution in the Connecticut and Merrimack Rivers rendering them unnavigable. We must never go back to the BAD OLD DAYS. 

I also have a child who fights fires in the Owens Valley Conservation district in the Eastern Sierra Nevada Mountains. It is a Fallacy to state that rescinding the roadless rule helps with wildfire mitigation. The fact is, where there are roads, and where the canopy is thinned out due to logging wildfires increase and spread much more easily. Where the soil is disturbed by road building, and by logging, fast growing succession species come in. These are all too often invasive species that smother trees and provide more fuel for fires. I have personal experience managing infestations of oriental bittersweet on my 200 acre property in New Hampshire. This plant destabilizes soil running under existing native trees and shrubs. It grows rapidly because it can spread by seed, rooting, or cuttings. It quickly overtakes trees, blocking the light and killing them, creating more fuel for fires. The roadless rule preserves ecosystems and old growth forests which in turn provides far better protection against wildfire than roads and the accompanying logging ever could. Furthermore, protecting and preserving road free forests protects the watershed. This in turn protects not only the wildlife that depend on clean water, but the people, too. We cannot escape that we, too, depend on clean drinking water. This is why water management districts are so strict about what activities are permitted near reservoirs and the streams that feed them. More roads leads to more pollution due and more erosion. We must not allow this to happen. Finally, as someone who lived for several years in the Western Carolina mountains before moving to Florida, I urge you to protect the sensitive and diverse ecosystems that are in our National Forests. There are more species of flora and fauna in the Southern Appalachians than in the entire continent of Europe. Many exist there alone. Alpine, desert and wetland areas, too are fragile and must be protected. Once gone, they are gone for good. As I am a Christian, I believe we must respect and protect God’s creation, not destroy it for our own selfish and short sighted desires. Please, preserve the Roadless Rule as it is. DO NOT RESCIND IT.

I'm am commenting in opposition to removing the Roadless Area Conservation aka 2001 Roadless Rule. This is an important national conservation policy that should stand as written. Here is what will be lost if the Roadless Rule is rescinded: Clean Water: Protects drinking water sources and vital watersheds for tens of millions of Americans by preventing industrial erosion and stream sedimentation. Critical watersheds like the Rio Grande basin in New Mexico. Wildlife Protection: Preserves unfragmented, natural habitats for hundreds of endangered, threatened, and vulnerable species, including native trout and mammals like the Mexican Grey Wolf. There are currently threats to the Endangered Species Act. This is another attempt to harm already dwindling wildlife habitats. Wildfire Prevention: Limits human-caused ignitions and destructive activities, as scientific data shows wildfires are significantly less likely to start in roadless areas than in roaded forests. There are currently not enough "local" USFS employees to protect and manage the Cibola National Forest so presenting this as a way to make decisions at a local level isn't the truth. Backcountry Recreation: Safeguards pristine landscapes that support outdoor activities like hiking, bird watching, hunting, and fishing. There are economic benefits to local communities that are greater than the quick extraction of limited resources. My family enjoys visiting the Cibola National Forest weekly and hiking from the road into areas within the roadless areas to explore the natural sounds of the forest. Through the last decade it has gotten harder and harder to escape ATVs when visiting the Mount Taylor region. This time away from day to day pressures brings all of us peace. A quick AI search will show you that even it understands what will be destroyed by adding more roads into our public lands within the national forests. Many public lands already allow mining, grazing, and logging. Humans depend on these resources for homes, food, jobs, etc. The roadless rule protects "other" areas of public lands from logging, grazing, and mining by not allowing roads. Determining what areas should be roadless or mixed use or strictly preserved is a carefully planned, scientific process so humans and other species get the most long term benefit. The 2001 Roadless Rule followed that process and needs to remain as is for us and future generations.

I live in New Mexico and my family of six’s first choice for recreation is always to enjoy the public recreation lands that are abundant in the state. We hike, backpack, fish, hunt, cross country ski, downhill ski, camp, and mountain bike. In addition, our house is one undeveloped lot removed from the Cibola National Forest and about a half mile from the Sandia Mountain Wilderness area, so the fire mitigation status of the national forests are of critical interest for us. I am attaching a view of our neighborhood from Cibola National Forest. I am commenting to oppose the removal of the Roadless Rule. My family’s main concern with the removal of the Roadless Rule is that wildfire management will not be improved and that wildfires will in fact increase. Wildfire risk is documented to be higher in areas with roads (1, 2). Furthermore, according to a white paper by Trout Unlimited (3) the portion of current Roadless Rule areas that have been treated for wildfire mitigation (3.5%), while less than the managed areas with roads (4.5%), is 75% of the managed area with roads so the lack of roads is not impacting forest management too significantly. Our recreational use of the national forest and the safety of our home may both be impacted by wildfires in the future, so these two facts together are the primary driver of my opposition to repealing to Roadless Rule. Secondly, repealing the Roadless Rule would be fiscally irresponsible. The roads that the Forest Service already is responsible for needed $8.6 billion in maintenance (4) as of 2023; it is irresponsible to build further roads when the ones already in existence cannot be maintained with current budgets. Finally, animals rely on these areas without roads. They constitute only 30% of the Forest Service managed area, and only 2% of the total land area of the United States. Surely we can leave 2% of the ecosystem intact? Given the above facts, I surmise the only motivation to remove the rule is to open up those small areas of the country that we have not already exploited for further extraction of resources to make money. This is not good stewardship of the land or resources. In conclusion, please do not remove the Roadless Rule, it will lead to increased wildfire risks, less maintenance on already existing roads, further reduction of crucial habitat, and money to further line the pockets of those who thrive off of the exploitation of the earth. 1.Cardille, J.A.; Ventura, S.J.; Turner, M.G., 2001. Environmental and social factors influencing wildfires in the Upper Midwest, United States. Ecological applications, 11(1), pp.111-127. 2. Aplet, G.H.; Hartger, P; Dietz, M.S., 2026. Three-decade record of contiguous – U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22:8. 3. Roadless Active Management and Fire: A GIS data analysis and research review, Trout Unlimited, 2026 4. Maintaining Infrastructure https://www.fs.usda.gov/science-technology/infrastructure/maintaining

I live in New Mexico. I am six years old. I like to climb trees and rocks in the National Forest. I also like to ski in the National Forest, I am attaching a picture of me and my friends cross country skiing in the Cibola National Forest. I think you should keep the Roadless Rule. The Roadless Rule helps animals have a place to live. There will be more wildfires if the Roadless Rule is repealed. It will be bad for the environment if it is repealed. We should keep the Roadless Rule.

We oppose the USDA's proposal to rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule). Overturning something like the Roadless Rule can never be undone. We are directly affected, as are our five children and seventeen grandchildren, and their children and grandchildren. We are residents of rural New Mexico in part because of the vast untouched areas. We hike and paddle often in forest, BLM, and wilderness areas in multiple states. We visit the Gila National Wilderness, Cibola National Forest and the Wild and Scenic Chama River multiple times each year. The DEIS concedes the no-action alternative maintains the most opportunities for quiet, remote and self-reliant recreation. This is important to us. The DEIS also cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, 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. This is important to us. Finally, where we live in rural New Mexico, wildfire is a significant risk. Road access will increase the number and frequency of wildfires. The agency’s own analysis, 2014 to 2024: human-caused ignitions run 22.4 per million acres per year on roaded national forest land, against 3.0 inside the affected roadless areas. The agency's own conclusion: “human caused ignitions increase in abundance with proximity to roads". Please drop this proposition. Thank you for your attention. Doug and Kellee Summers Pie Town, NM

The trails through Cibola, Santa Fe, and Carson National Forests are where my partner, our friends, and I spend our time watching birds, looking for elk, deer, bears, and coyotes. The wildness that makes those forests worth hiking into depends directly on the roadless protections this proposal would eliminate, and I oppose rescission of the 2001 Roadless Area Conservation Rule. The agency's treatment of alternatives in this environmental review is the most serious procedural failure here. As stated in the Alternatives Considered but Eliminated from Detailed Study section, "An alternative that considered maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was considered but eliminated from detailed study as not being responsive to the purpose and need." That rationale is circular. The purpose and need was written to require deregulation, so any alternative that preserves meaningful protection is defined out of contention before analysis begins. An alternative that allows temporary-road-based hazardous fuel treatment and selective harvest inside inventoried roadless areas, without authorizing permanent roads, could plausibly meet the agency's stated fire and forest-health objectives without destroying the landscape values that bring people like me to Cibola National Forest. The agency must explain, in non-circular terms, why such an alternative cannot meet those objectives, and must add it to the range of alternatives analyzed in the final EIS. The agency's reliance on land management plans as the primary safeguard under alternatives 2 and 3 is equally troubling. The Potentially Affected Environment section concedes that "45 of those were revised between 2001 to 2011 when the status of the Roadless Rule was uncertain due to litigation. Therefore, these plans are less likely to have incorporated IRAs into their management areas or provided specific direction for these areas." The agency cannot simultaneously claim that existing plans will protect inventoried roadless areas and acknowledge that most of those plans were developed without adequate roadless-specific direction. Before any rescission is finalized, the agency should identify in the final EIS which specific plan amendments or revisions would be required to provide equivalent protection for each affected forest, and should not move forward until those updates are completed or a binding schedule for completing them exists. The birds and wildlife I watch in these forests do not recognize the difference between a rescinded federal rule and a plan revision that has not yet happened. Clean water, responsible use of public funds, and the long-term integrity of national forest landscapes are all bound up in this decision. I ask that the agency treat each of these points as requiring a substantive response before it takes final action.

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 There is nothing like being in the forest alone, no crowds, just you and your spouse, listening for the call of an owl under dark skies. That is what the Cibola National Forest means to us. The proposal to rescind the 2001 Roadless Area Conservation Rule would put that at risk, and I oppose it. The threat I want to name first is fire. The agency justifies this rescission partly on wildfire and fuels management grounds, but its 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 Cibola is already under pressure, including from uranium prospecting that I believe represents exactly the kind of intrusion this rule was written to prevent. Opening roadless areas to new construction does not reduce fire risk; the agency's own data say it increases it. I ask that the agency explain why this proposal departs from those prior findings, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. Our water comes from the Cibola National Forest, and we must protect it. The agency's own record establishes that roads and their facilities can produce the overwhelming share of sediment from a timber sale, yet the economic case for rescission is thin at best. The agency's own text concedes: "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 that admission with its own cost-benefit analysis, which 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, a net present value spanning -$92 million to +$199 million, and a road system already carrying a $6.9 billion maintenance backlog. How does an action whose own analysis cannot establish a net benefit justify expanding that system at the expense of watersheds that are still largely unimpaired? I also want to note that the rule the agency proposes to eliminate already contains the flexibility it claims to need. 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)." If specific permitting situations remain unaddressed by those exceptions, the agency has not identified them with any precision. I ask that it do so: name the specific burdens not already covered, and quantify them. Finally, the small-business certification attached to this proposal is not credible on its face. The agency certifies no significant impact on small entities while its own 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. Spreading that loss across every small firm in the sector nationally, rather than examining the guides and outfitters who actually hold permits in the affected areas, produces a meaningless average. The agency should withdraw that certification and assess the firms actually operating in these places. These roadless areas are, as I think of them, the jewels of our nation, found nowhere else. The Forest Service held more than 600 public meetings and took in 1.6 million comments to build the rule. It has held none to undo it. These are places where children can learn to love and appreciate what is still intact, places that bring something steady and grounding that developed land simply cannot. Letting uranium prospectors and road builders into the Cibola's roadless lands is not a trade I accept, and I ask that the agency address each of the concerns above directly and in full before this proceeding closes.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I hike, camp, and backpack extensively trough roadless areas, and the peace and freedom these lands offer is unparalleled. Maintaining the roadless status of these lands is essential to preserving this quintessentially American public asset for our children for generations to come. My wife and I hiked a portion of the Continental Divide Trail (a National Scenic Trail, established by congress) for our honeymoon. Over 300 miles of the CDT pass through pristine roadless lands on superb trails. Public land should NOT be exploited for the profit of private profiteers who have not stepped foot in these lands and appreciated their unique assets. By building roads through these lands, it increases the amount of human-wilderness boundary and thus increases the likelihood of destructive effects, such as wildfires, floods, land and water degradation, and loss of biodiversity/wildlife habitat. My wife and I recently welcomed our son to our family, and it would make me proud to pass down an America to his generation that has the heritage, history, integrity, and beauty of its public lands intact. The current proposal forces mismanagement onto our public lands and is threat to our American heritage. I live near roadless areas in the Santa Fe National Forest and was evacuated from my home during the Hermits Peak-Calf Canyon fire. Our community does not need the increased fire risk and the burdens that come with it that the current proposals will force onto us. My family has hiked in the Mt Evans area many times and some of our fondest memories come from camping near Abyss Lake, watching the sunsets and sunrises kiss the glorious peaks of Mt Bierstadt and Mt Blue Sky, crown jewels of America's public lands. The Gila is an amazing place to go backpacking, with some of the most pristine wildlife habitat (and its resultant wildlife) I have ever seen. The Bear Mountain area is local to me, and my family and I hike here frequently, taking in the freedom and relaxation that a roadless area provides and enjoying the resurgent forest and its wildflowers and wildlife. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Mt. Evans Adjacent Area (10,247 acres), Arapaho-Roosevelt NF, Colorado - Enchanted Lakes (1,276 acres), Santa Fe NF, New Mexico - Bennet Mountain / Blowout / Willow Creek / Lion Point / Gree (53,053 acres), Rio Grande NF, Colorado - Contiguous To Black & Aldo Leopold Wilderness (111,883 acres), Gila NF, New Mexico - Sawyers Peak (59,743 acres), Gila NF, New Mexico - Candian River (7,149 acres), Cibola NF, New Mexico - Bear Mountain (1,387 acres), Santa Fe NF, New Mexico - Valle Del Toro (1,862 acres), Santa Fe NF, New Mexico 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 of the road construction and timber harvest it would newly allow. Some of the areas named above lie in Idaho or Colorado, where the state-specific roadless rules at 36 CFR 294 Subparts C and D are stated to be retained. For those areas I ask that the agency state in the DEIS precisely how this action interacts with the retained state rules and what, if anything, changes in their management. Additionally, I raise the following issue for the record and ask that the agency respond to these concerns: Issue: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. 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. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. 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. 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, Calj Umezono Las Vegas, NM

Re: RIN 0596-AD66; Docket No. FS-2025-0001 To USDA and the U.S. Forest Service: I strongly oppose rescission of the 2001 Roadless Area Conservation Rule and urge USDA to select the No Action Alternative and retain the Roadless Rule. Rescission is inconsistent with scientific evidence concerning roads, watershed health, aquatic habitat, and wildfire risk. New Mexico contains hundreds of thousands of acres of Inventoried Roadless Areas (IRAs) protecting headwaters, wildlife habitat, and intact landscapes. The Gila National Forest alone contains 733,836 acres in 29 IRAs, including Devils Creek, Frisco Box, Eagle Peak, Meadow Creek, Gila Box, Lower San Francisco, and areas adjoining the Gila and Aldo Leopold Wildernesses. Other important IRAs include Ryan Hill, Apache Kid, San Jose, and Datil on the Cibola NF and South Guadalupe Mountains, Little Dog and Pup Canyons, and Ortega Peak on the Lincoln NF. Protecting intact headwaters is particularly important in arid New Mexico. Roads are major sources of sediment and watershed degradation. They compact soils, concentrate runoff, and deliver sediment to streams. Reid and Dunne (1984) found a heavily used gravel road produced approximately 130 times the sediment of an abandoned road, while Motha et al. (2003) found unsealed forest roads produced 20–60 times more sediment per unit area than undisturbed forest. Fine sediment degrades aquatic habitat by filling pools and embedding streambed gravels. Roads and stream crossings also fragment aquatic habitat and alter watershed processes. Jones et al. (2000) documented road effects on hydrology, geomorphology, and stream networks. Warren and Pardew (1998) found culvert and slab crossings reduced fish movement compared with natural stream reaches. This is especially concerning in New Mexico, where perennial aquatic habitat is already limited. USDA's wildfire rationale also fails to account for roads increasing wildfire ignitions. Balch et al. (2017) found humans caused 84% of recorded wildfires in the conterminous U.S. in their 1992–2012 dataset. Aplet et al. (2026), specifically examining National Forest lands, found wildfire ignition density of only 1.97 fires/1,000 ha in IRAs versus 7.99 fires/1,000 ha within 50 meters of roads. Human-caused ignition density within 250 meters of roads was more than three times greater than beyond 500 meters. Building roads into roadless areas therefore risks creating more fires through increased human access. Modern wildfire suppression also does not require permanent roads into every landscape. Smokejumpers, helitack, helicopters, airtankers, hotshots, and other resources allow firefighters, equipment, water, and retardant to reach remote fires. Roads remain useful, but new permanent roads are not a prerequisite for effective wildfire response. The Roadless Rule already provides exceptions for roads needed to address imminent threats from wildfire and other catastrophic events. New roads also create taxpayer liabilities. USDA acknowledges a $6.9 billion deferred-maintenance backlog for existing roads and bridges. Building more roads creates continuing costs for culverts, drainage, erosion repair, stream crossings, and eventual decommissioning. Finally, these National Forests belong to the American public. The original Roadless Rule followed approximately 1.6 million public comments. Public support remains overwhelming: a 2026 national survey reported 76% of likely voters supported the Roadless Rule and only 13% opposed it. These remaining roadless lands are a scarce national resource, not simply acreage awaiting development. I therefore request that USDA withdraw the proposed rescission and select the No Action Alternative, retaining the 2001 Roadless Area Conservation Rule. USDA should fully account for road-related sediment, altered hydrology, aquatic fragmentation, increased human-caused wildfire ignitions, and long-term maintenance costs. The scientific record does not demonstrate that eliminating national Roadless Rule protections is necessary for wildfire management or forest health. Please retain the Roadless Rule and protect these public lands for current and future generations. References: Reid & Dunne (1984), Water Resources Research 20:1753–1761; Motha et al. (2003), Water Resources Research 39; Jones et al. (2000), Conservation Biology; Warren & Pardew (1998), Transactions of the American Fisheries Society 127:637–644; Balch et al. (2017), PNAS 114:2946–2951; Aplet et al. (2026), Fire Ecology 22:8.