Read the comments.

I strongly oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in Flagstaff, Arizona, and the Coconino National Forest means so much to me. I've spent countless days hiking there, enjoying the physical and mental health benefits of being in nature. As someone with a collegiate degree in sustainability, I also oppose rescinding the roadless rule because it will drastically fragment ecosystems and negatively impact biodiversity and overall ecosystem health. There are many studies demonstrating that ecosystems less fragmented by human development are the most resilient due to their unimpeded connectivity. The forests and various lands that the Roadless Rule protects aren't just clumps of individual trees or bushes: they are connected to a larger system that depends on each of its parts to thrive. We rely on many ecosystem services that thriving ecosystems provide, such as clean air, clean water, reliable food sources, and carbon sequestration. Rescinding the Roadless Rule would not only degrade the forests that the American public has the right to enjoy, but it would also impact ecosystem and, consequently, societal health due to its negative impacts on ecosystem services we rely on.

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I have lived in Sedona, Arizona for 16 years. My wife and I run a small business hosting visitors who come here for one reason: the land. The Coconino National Forest surrounds our town. Our guests come to hike it, photograph it, and get away from roads and noise. Wild, unroaded forest is not a luxury here. It is the local economy, and it is why people live here. The 2001 Rule was not handed down overnight. It came out of years of hearings and more than a million public comments, and the public's answer was clear: keep the last roadless places roadless. Throwing that out with a short comment period and almost no public hearings disregards the people who own these lands — all of us. The stated goal is "flexibility" and "reducing regulatory burden." In practice, removing a national standard means each roadless area becomes a fresh fight, forest by forest, under pressure from whoever wants to build or log there next. Protections that can be undone one plan at a time are not protections. The Forest Service already cannot maintain the roads it has. It carries a multi-billion-dollar maintenance backlog. Building more roads into some of the last intact land makes that worse, not better. Roads bring erosion, sediment in streams, invasive weeds, and more human-caused fires. The 2001 Rule already allows work to reduce wildfire risk, so rescinding it is not needed for fire safety. These roadless areas protect clean water, wildlife habitat, and some of the last quiet places left in this country. Once a road goes in, that land is never roadless again. That cannot be undone by a future plan. I urge USDA to withdraw this proposal and keep the 2001 Roadless Rule in place. Traci Quebbeman Sedona, Arizona

Dear USFS Personnel, I support Alternative 1 and demand that the 2001 Roadless Area Conservation Rule be retained. I live near and visit on a weekly basis the roadless area on the western and southern sections of the Southern Massanutten roadless area in the Lee Ranger District of the George Washington National Forest of Virginia. Wild, roadless places like it are why I chose to live in and support the economy of the Shenandoah Valley. The Southern Massanutten and other nearby roadless areas protect the headwaters that supply my daily drinking water, including my town of Harrisonburg’s Switzer Reservoir, and these areas support the outdoor recreation economy my community relies on. The US Forest Service and cognizant state-level agencies already cannot keep up with the forested areas that already have roads. Please don’t add more roads. Please limit risk to personal property by keeping the Roadless Rule intact. Furthermore, rescinding the roadless rule poses an unacceptable risk to personal property and health that the USFS has yet to address adequately. My home was positioned within three miles of the 2019 Museum Fire in Flagstaff, Arizona, which burned 1,961 acres of the Coconino National Forest (1). I personally suffered from the increased smoke during the fire, and in 2021 heavy monsoon rains resulted in catastrophic flooding due to the reduced absorptive capacity of the Museum Fire burn scar (2). The Museum Fire was started by an excavator clearing trees in a forested area. Just one year after the Flagstaff floods of 2021, the Pipeline Fire was started in the same area just north of the town of Flagstaff, AZ by a man intentionally lighting toilet paper on fire in the forest despite "no campfire" signs being posted throughout the forest due to fire-prone conditions (3). The Pipeline Fire quickly grew to over 25,000 acres and resulted in evacuations and property loss. No less than 78% of human-caused wildfires on National Forests start within ½ mile of a road, and if the Roadless Rule is rescinded, road construction in roadless areas is likely to lead to more human-caused wildfire (4). The two cases recounted here shows that we cannot trust professionals or civilians to avoid starting forest fires, and that if people have easy access to the land via a road, the chances for catastrophic wildfire simply increase. I call on those who would advocate for rescinding the Roadless Area Conservation Rule to show that the likelihood of wildfire risk increasing after rescinding the Roadless Area Conservation Rule is at maximum 1/1,000,000. If this cannot be accomplished, it is arguably unconscionable to rescind the Roadless Area Conservation Rule. Where I live in Virginia, the risk of wildfire may be lower than in Arizona, but there is a substantial wildland-urban-interface and flammable forest material on the landscape. Each year in Virginia, more than 60 homes and other structures are damaged or destroyed by wildland fire (5). The USFS is dubiously promoting rescission of the Roadless Area Conservation Rule as wildfire protection, but its own effects analysis is in contradiction with its assertion of wildfire protection. The agency must quantify the expected increase in human-caused ignitions resulting from new road access and weigh it explicitly against the claimed reduction in wildfire hazard before that rationale can bear any weight. Problematically, the USFS's own Cost Benefit Analysis Table 4 (p. 30) lists among the qualitative unquantified costs of the Roadless Area Conservation Rule recission proposal: "Degraded recreation quality; ecological and water impacts; increased ignition risk; and agency road maintenance burden." The agency says it cannot quantify reduced wildfire risk, and since ample data show that land with roads burns at a far higher human-caused rate than land without roads, I call on the USFS to get serious about quantifying the net wildfire effect of rescission before leaning on the wildfire reduction argument to justify the proposal to rescind. Considering the logic noted above and the fact that the August 20, 2026, DEIS fails to fulfill NEPA requirements (42 U.S.C. § 4321), I demand that the U.S. Forest Service withdraw the proposal to rescind the Roadless Area Conservation Rule to avoid violation of the Administrative Procedure Act (5 U.S.C. § 706(2)(A)). Numbered references: 1. 2019 Museum Fire (https://www.weather.gov/fgz/MuseumFire2019) 2. 2021 Flooding following Museum Fire (https://www.swfireconsortium.org/2022/03/25/post-fire-flooding-the-museum-fire/) 3. Pipeline Fire (https://www.fox10phoenix.com/news/pipeline-fire-man-pleads-guilty-starting-wildfire-flagstaff) 4. USA 2025, S_USA.FireOccurrence (https://data.fs.usda.gov/geodata/edw/datasets.php?xmlKeyword=National+USFS+Fire+Occurrence+Point) 5. Wildfire in Virginia (https://www.dof.virginia.gov/wildland-prescribed-fire/learn-about-wildland-and-prescribed-fire/wildfire-in-virginia/)

I am opposed to changes to the roadless rule. It is a significant measure that has been effective in preserving and managing natural resources, hiking, fishing and hunting opportunities that the public enjoys and support. I have been a visitor to national forest lands in Colorado (Uncompahgre NF, Rio Grande NF, White River NF), Utah (Dixie NF, Fishlake NF), California (Sierra NF, San Gabriel NF, others), Arizona (Coconino NF, Kaibab NF), others. I support the roadless rule and I don’t support eliminating it. Yes, the President’s donors may be trying to benefit from removing the rule, but a majority of the public supports preserving it. Utah politicians like Lee may claim no one supports measures like the roadless rule, but he is undoubtedly pandering to outside interests.

I am strongly opposed to the elimination of the roadless rule on public lands. I have lived in the Rio Grande National Forest, walking distance from the designated Weminuche Wildnerness, as well as the Coconino National Forest. There are already plenty of roads for resource extraction and recreation. More roads means more logistical, maintenance, and pollution problems. The reason these lands are protected is because they have things like nowhere else. More roads is not the answer to the problems of public lands. This was one of the most commented on and supported rules when it was proposed about twenty years ago. Do not change the rule now. It is still overwhelmingly popular with the people who live in and visit these places and surrounding communities.

I'm a retired USFS employee who worked on the original Roadless Rule. I worked on the Coconino NF, which is heavily roaded already. - The areas defined as "roadless" were roadless for a reason.... it didn't make sense, economically or environmentally to build roads there. - Recent Coconino NF research indicated most human-caused fire ignitions occurred adjacent to roads. So more roads will mean more human-caused fires.

10/6/2026 Under Secretary Michael Boren United States Department of Agriculture 1400 Independence Ave. SW Washington, DC 20250 Chief Tom Schultz United States Forest Service 1400 Independence Ave. SW Washington, DC 20250 Dear Under Secretary Boren and Chief Schultz, I am writing to express my strong opposition to the Department of Agriculture’s proposed revisions to the 2005 Travel Management Rule, as outlined in the recent Notice of Intent (NOI). Living right on the edge of the Coconino National Forest, I experience firsthand the vital importance of balanced, thoughtful land management. As an avid mountain biker who spends countless hours on the trails here in Arizona, as well as exploring the incredible national forests of California, Utah, New Mexico, Idaho and Colorado, I know how essential clear, well-managed travel plans are for protecting the quality of our public lands and the outdoor recreation economy. For over two decades, the 2005 Travel Management Rule has successfully provided a framework where diverse user groups—hikers, mountain bikers, hunters, anglers, horseback riders, and motorized recreationists—can coexist. Reversing this framework will endanger public safety, damage wildlife habitat and clean water resources, and degrade the quiet, non-motorized recreation opportunities that millions of visitors depend on. Any updates to travel management must preserve the following core principles: Maintain the closed-unless-designated default: Flipping the rule to make routes "open unless designated closed" would lead to a web of user-created trails, destroying natural vegetation, harming wildlife, and eroding non-motorized trail experiences. Protect natural and cultural resources: Decisions must prioritize soil health, watersheds, and wildlife habitats while minimizing conflicts between different user groups. Ensure robust local and public input: Local residents, mountain bikers, recreationists, Tribal Nations, and local communities must have a meaningful voice in access decisions. Maintain clear route designations: Clear signage, up-to-date digital Motor Vehicle Use Maps (MVUMs), and user education are essential so visitors know where motorized access is permitted. Account for long-term maintenance costs: The Forest Service already faces a massive backlog in trail and road maintenance. Expanding motorized routes without guaranteed resources for upkeep places an unfair burden on taxpayers and local land managers. The existing rule already provides a clear, public process to modify routes and update Motor Vehicle Use Maps as local needs change. We do not need a sweeping rule change that jeopardizes sensitive landscapes and quiet recreation across the American West. I ask the Forest Service to uphold these protective principles so that our national forests in Arizona, Utah, Colorado, and across the nation remain healthy, accessible, and safe for generations to come. Sincerely, Thomas Turnbull Flagstaff, Arizona

44.7 million acres of our forests are managed under the roadless rule, about 30% of our national forests. The roadless areas we have in Northern Arizona are amazingly diverse. With that said the Coconino NF has more roads than we can count. - The Forest Service already has more roads than they can maintain. Estimated costs for annual maintenance 1.6 billion, the agency receives less than 20% of that per year - The incidence of human caused fires generally increases in proximity of roads - Roads effect biodiversity by causing habitat fragmentation and loss of connectivity. Elk prefer roadless areas and select habitat away from roads - While fires tend to be larger in roadless areas the amount of moderate to high severity burns is only slightly higher in wilderness and roadless areas.

I am an Arizonan and I recreate on public land almost daily. Public lands are central to the lifestyle and traditions that citizens like myself deeply value as Americans. I recreate on the Coconino NF, Kaibab NF, Tonto NF, Coronado NF, Prescott NF and the Apache Sitgreaves NF. I am an angler, hunter, backpacker, archer, recreationist, and roadless areas are central to my way of life. It is imperative that backcountry areas are conserved for my children's generation and for generations to come. As a scientist, I believe that the rationale behind rescinding the roadless rule is built on faulty logic and poor presumptions instead of evidence. The rescission of the Roadless Rule is dangerous and not backed by solid science. The benefits of the Roadless Rule as they are written protect wildlife, watersheds, ensure proper wildfire management, protect clean water while providing the flexibility land managers need. The Roadless Rule does not limit active forest management. Land managers are able to treat high fuels areas while preventing the construction of permanent roads. The data clearly show that wildfire risk increases in areas with roads. I support scientifically informed forest management from local experts who understand the impacts of recreation and forest health. Eliminating the Roadless Rule is dangerous and puts our forests, citizens, wildlife and firefighters at greater risk. In Arizona, wildfire ignitions are nearly seven times more likely near roads according to a report from The Wilderness Society. Introducing new road systems will increase fire frequency and put our fire fighters in harms way. The impact of rescinding the Roadless Rule will affect 45 million acres of land while federal land management agencies remain underfunded and understaffed. This proposal is being made while the Forest Service is experiencing a major reorganization including the elimination of regional offices, relocation of staff and a reduction in force. How does removing long-standing protections amid a major agency restructuring benefit the American people and the lands we all share? It does not. Thank you for the opportunity to comment on the Roadless Rule.

Do not cancel roadless rule protections in our national forests. I have lived adjacent to the Coconino National Forest for 45 years and the roadless rule restrictions are valuable to all of us.

I write today in strong support for the no action alternative and the 2001 Roadless Area Conservation Rule. The Roadless Area Conservation Rule is popular, its conservative, its responsive to local and national needs, and its working. Our National Forests have only remained intact because of this 25-year-old commitment not to build roads in these areas. The Forest Service contends that more roads means improved wildfire suppression effectiveness, and therefore rescinding the roadless rule would be a beneficial action for these roadless areas. Yet, rescinding the roadless rule wont prevent wildfire. Just the opposite, in fact. More roads mean more human-caused wildfires. 90 percent of all wildfires start within one mile of a road, and wildfires are four times as likely to ignite in areas with roads than roadless areas. It is highly likely that, on balance, more roads would increase -- not decrease -- the negative fire impacts on wildlands and wildlife in national forests. For decades I have been fortunate enough to traverse roadless areas in national forests around the West -- on foot, on skis, on snowshoes, and in rafts -- from Arizona to New Mexico to Utah to Oregon to Idaho. I've seen wildlife in these places that I've never seen anywhere else. I've experienced solitude and profound quiet in roadless areas that can't be quantified or monetized. Roadless areas not only contain the best intact habitat for countless fish and wildlife species, they are also important to me as a place to recreate, relax, recharge, and recommit to taking care of this gift of a planet we live on. Without these places and the water, plants, animals and other essential elements that they provide humankind, we would certainly perish as a species. I urge you not to erase protections for our roadless areas, which are home to most of our last remaining old-growth forests in America. Protecting them is more important than ever in light of hotter and drier weather. I live in Flagstaff, Arizona, where my property abuts the Coconino National Forest and I walk my dogs every morning on trails in the largest ponderosa pine forest in the world. I watch the forest get drier every year, and fear for the future of our beautiful ponderosa pines. More roads in the Coconino would inevitably mean more catastrophic fires, and threaten my home and habitats for many species who are already struggling to make it in a drier climate. And as a resident of Flagstaff, I have a vested interest in protecting the roadless areas of the San Francisco Peaks within the Coconino, which provide us with three-quarters of our drinking water (which is the best tasting water I've ever consumed). Without the water that falls as rain and snow on these mountains making its way unpolluted through the volcanic rock of the Peaks and into our homes, Flagstaff would be in serious trouble. Across Arizona, roadless forests are oases for a remarkable concentration of threatened and endangered species such as Mexican gray wolves, Mexican spotted owls, Gila trout, jaguars, Chiricahua leopard frogs, and Mount Graham red squirrels. We need to protect these species and a myriad of other endemic and migratory species -- here in Arizona, and across the country -- that count on unspoiled habitats, migration corridors and resources of the national forests for their survival. Opening up the national forests to more roads means more logging, more wildfires, more mining, more drilling, less solitude, less quality recreation opportunities, and more money out of the pockets of taxpayers like me to build and maintain additional roads. I'm not in favor of all that just for "increased local management flexibility." Properly managing our national forests means protecting many of their key resources and values, not degrading them. Roadless areas and the protections afforded to them by the Roadless Area Conservation Rule are critical to our high quality of life. The rule itself is enormously popular. It is supported by millions of Americans, and it has stood the test of time. This attempt to eliminate protections for our public lands is bound to be unpopular, just like Congress failed attempt in 2025 to sell our public lands. Americans are paying attention, and we want our roadless areas left alone. I am one of the millions of Americans who oppose opening roadless areas to road building, commercial logging, mining, and drilling. Its not too late to abandon this unpopular, unscientific, and unwise effort to sacrifice our public forests. I urge you not to rescind the Roadless Area Conservation Rule. Please choose the no action alternative. Sincerely, Pamela Hyde Flagstaff, Arizona

Please do not rescind, roll back, or reduce the application of the Roadless Rule to our federal lands. I have hiked in forested lands in Arizona, Utah, Alaska and California (Coconino National Forest, Muir Woods, and many more), enough to learn that there is no redundant space in them to be used as roads or cleared for timber. Every fallen tree and the smallest puddle feeds new growth, birds, insects, mammals that keep the forest alive. Take out any piece of the puzzle and the system no longer functions. Ancient forests can't be replaced by "new" ancient forests for hundreds to thousands of years, and the result is desert. If nothing else, consider the monetary loss of watershed, tourism dollars, and research. DO NOT ROLL BACK THE ROADLESS RULE.

Date: September 30, 2026 To: National Roadless Program Manager, USDA Forest Service Subject: Strong Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule (Docket No. FS-2025-0001 / RIN 0596-AD66) I am writing to express my vehement opposition to the proposed rule to rescind the 2001 Roadless Area Conservation Rule. I strongly urge the U.S. Forest Service (USFS) to retain these crucial protections for our remaining intact backcountry lands. As a resident concerned with the management of the Coconino National Forest and surrounding public lands in Coconino County, Arizona, I believe this rollback will yield exclusively negative impacts on our environment, communities, and fiscal resources. 1. Inadequate Staffing, Budget Cuts, and Off-Road Vehicle (ORV) Abuse The Forest Service lacks the structural capacity, personnel, and budget to manage and regulate existing motorized use, let alone police newly opened backcountry areas. • Existing Damage: Motorized recreational users already have ample access to designated ORV areas. In these "sacrificed" zones, the ground is visibly denuded, soils are heavily compacted and carved up, and natural habitats are severely degraded. • Enforcement Failure: Even in areas where motorized vehicles are legally restricted to existing routes, rules are blatantly and routinely ignored. Unauthorized off-trail driving is common, resulting in severe degradation of wildland areas, sensitive wildlife habitats, and irreplaceable archaeological sites. • Budget Realities: Recent federal budget cuts have left the USFS severely short-staffed. Opening pristine, roadless areas to potential resource extraction and road construction invites unchecked abuse. The agency simply does not have the law enforcement personnel or monitoring resources to prevent illegal motorized incursions into these newly vulnerable zones. 2. Escalating Human-Caused Wildfire Risks and Budget Strain The environmental analysis must fully account for the direct correlation between increased vehicular access and human-caused wildfires. • Ignition Corridors: Opening remote areas to motorized vehicles opens the door to increased human-caused ignitions in areas that are currently difficult for firefighting crews to access quickly. • Fiscal Burden: The national wildfire suppression budget is already profoundly overtaxed. The economic and ecological impacts of catastrophic wildfires are astronomical. • Community Vulnerability: For communities in Coconino County nestled within the wildland-urban interface, increasing the threat of catastrophic wildfire directly endangers homes, human lives, and critical municipal watersheds. 3. Substantive Threats to Coconino County’s Resources In Coconino County, the 50,000 acres of Inventoried Roadless Areas (IRAs)—including ecologically vital zones like East Clear Creek—are irreplaceable. • Archaeological and Cultural Protection: Coconino County holds one of the densest concentrations of cultural and historical artifacts in the nation. Without the strict prohibitions of the 2001 Rule, these sacred and historic sites face permanent destruction from unauthorized off-road driving and resource development. • Watershed Integrity: Our local forests serve as the primary source of clean drinking water for the region. Removing protections will accelerate erosion from logging roads, damage delicate riparian habitats, and threaten regional water security. The 2001 Roadless Rule already contains flexible provisions that allow the Forest Service to perform necessary hazardous fuels reduction and public safety projects without building permanent infrastructure. Rescinding the rule entirely is an unnecessary step that trades long-term ecological health and fiscal responsibility for short-term exploitation. I request that the Forest Service withdraw this proposed rescission and maintain the 2001 Roadless Area Conservation Rule in its entirety. Sincerely, Judy and Pete Weiss

As a longtime resident of Flagstaff, Arizona, a city surrounded by the Coconino National Forest and other forest ecosystems, I would like to enthusiastically oppose the proposed action to rescind in its entirety the national 2001 Roadless Area Conservation Rule. Although I have read and considered the reasoning around lifting this rule, I believe it is not supported by any clear evidence. However, reopening old forest roads and areas to motor vehicle recreation creates several notable problems. First, with the incursion of motorized use in these areas, it actually increases wildfire risk. In our arid region, it does not take much to spark a wildfire, and parked and idle vehicles have been known to cause ignitions. Plus, the act of more fully dispersing human travel and activity on the forests only increases the likelihood of human-caused wildfire. As demonstrated this year with the Pocket Fire near Sedona (cause yet to be determined, though ignition happened near a popular recreating site), any fire in any location can impact our area with smoke, closed roads and recreation areas, and the destruction of ecosystems. The expansion of motorized use also disrupts wildlife, which can have an impact on hunting and fishing (where such vehicles cross streams and disrupt the habitat). The lifting of the Roadless Rule also could lead to unintended consequences of recreationists seeing it as a "free-for-all," perhaps violating various laws around driving on unestablished roads or into wilderness areas. I hope those who are considering this will recognize the clear problems so they will not take the blame for what overturning the rule will inflict.

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge USDA and the Forest Service to withdraw the proposal and retain the Rule’s nationwide protections for inventoried roadless areas. I am a 36-year backpacker and hiker based in Sedona, Arizona, a certified site steward and trail patrol volunteer for the Coconino National Forest, a photographer who documents public lands, a board member of an environmental nonprofit focused on watershed protection, and an attorney with more than a decade of complex litigation experience. I have personally recreated in inventoried roadless areas in Arizona and Alaska, including along the Salt and Verde Rivers and in the Chugach National Forest. My attached PDF comment provides my complete factual, economic, environmental, and legal analysis, along with supporting authorities and citations. My comment raises several principal concerns with the proposed rescission. First, inventoried roadless areas provide a distinct recreational and ecological resource that cannot simply be replicated elsewhere in the National Forest System. Their undeveloped character supports primitive and semi-primitive recreation, wildlife habitat, watershed integrity, and water quality. Once roads and associated development are introduced, those characteristics may be permanently altered. Second, the proposal does not adequately account for the economic importance of outdoor recreation and undeveloped public lands. This omission is particularly significant in Arizona, where outdoor recreation is a substantial and growing component of the state economy. The attached comment discusses national and Arizona-specific economic data and explains why the economic value of recreation, watersheds, tourism, guiding, photography, hospitality, and related industries should be meaningfully considered before eliminating protections across 58.5 million acres. Third, forest-by-forest planning is not an adequate substitute for a uniform national baseline. Forest plans are revised infrequently and may be subject to differing local priorities, budgets, and political pressures. Replacing a national standard with separate management decisions across the National Forest System also makes it more difficult for recreational users, communities, and businesses to understand whether particular roadless areas will remain protected. The Forest Service should also address its substantial existing road-maintenance backlog before facilitating construction of additional roads into currently protected lands. Fourth, I question the proposal’s reliance on wildfire management as a justification for rescission. Research discussed and cited in my attached comment demonstrates a strong relationship between roads and human-caused wildfire ignitions, including Arizona-specific data showing that human-caused fires disproportionately occur near roads. If additional flexibility is necessary for hazardous-fuels treatment, USDA should consider narrowly tailored modifications to existing exceptions rather than eliminating national protections across ecologically diverse roadless areas. Finally, my attached comment identifies significant legal and procedural concerns under the Administrative Procedure Act and National Environmental Policy Act. These include whether the agency has adequately explained the reversal of a policy in place for approximately 25 years; meaningfully considered reliance interests; taken the required “hard look” at environmental, watershed, wildfire, recreation, and cumulative impacts; and provided an adequate opportunity for public participation given the scope of the proposed action and the abbreviated comment period. For these reasons, I urge USDA to withdraw the proposed rescission and retain the 2001 Roadless Rule. At minimum, the agency should extend the comment period, conduct additional public hearings, address the existing road-maintenance backlog, and revise its analysis to meaningfully consider recreation-economy impacts, watershed effects, wildfire ignition data, and reliance interests before taking final action. Please see my attached PDF comment for my complete comments, supporting factual analysis, legal arguments, authorities, data, citations, and personal stakeholder perspective. I respectfully request that USDA and the Forest Service consider the attached PDF in its entirety as my formal comment on the proposed rule.

As a firefighter, sportsman, and public lands owner in Nevada and Michigan, with respect I urge the rejection of this proposed roadless area rule. This rule would harm wildlife habitat and water quality in places my family and I use and care about like the Humboldt-Toiyabe NF, Coronado NF, Kaibab NF, Coconino NF, Inyo NF, Modoc NF, Umatilla NF, Huron-Manistee NF, Ottawa NF and Hiawatha NF and others. It will also likely increase risk of human-caused wildfires, most of which start near roads. This unwise, politically-motivated rule fails the broad public interest for conservation of US forests, watersheds and rural economies. Thank you, Daniel R Patterson, Indian River MI / Boulder City NV

The Roadless Rule protects nearly 1.2 million acres in Arizona, including roughly 140,000 acres on the Prescott National Forest and about 50,000 acres on the Coconino National Forest. These are the backcountry lands that surround residential areas in the Verde Valley. They are full of valuable ecosystems and biomes, wildlife (endangered and otherwise), and provide wilderness that invaluable to our spiritual and mental health, as well as the overall health of the earth. I firmly oppose repealing the 2001 Roadless Area Conservation. And you should also! It's our moral and ethical responsibility, as humans, to protect these areas for future generations. Thank you.

To the U.S. Forest Service, My name is Megan Mitchell, I live in the Coconino National Forest in Flagstaff, AZ. It will come as no surprise that I firmly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Repealing this rule would open an estimated 45 million acres to development and logging (this is similar in size to Washington state). I recreate on this land throughout the country. Frequently. From my own backyard around the Coco forest, to dispersed camping in UT, hiking in WA, backpacking in CO, and soaking in hot springs in NM. I find therapy and refuge in these spaces. Friends fill their freezers for their families with these areas. And my native brothers and sisters strongly oppose this proposal out of principle and respect for their culture and roots. Repealing the Roadless Rule would make my life considerably worse and I quite frankly am fired up and appalled at this continual threat. Below are reasons I disagree with repealing the act, and evidence-based information as support. Increased wildfire risk: This repeal is framed as a wildfire-safety measure, but the evidence does not support that claim. The vast majority of wildfires in the US are started by people. Studies have found that wildfires are ~four times more likely to ignite in areas with roads than in roadless forest. Over 90% of fires start within half a mile of a road. Research from the Pacific Biodiversity Institute and The Wilderness Society show that roads bring more vehicles, campfires, equipment sparks, and human traffic into forests that are the least fire-prone because they are remote. Opening these areas to roads will likely increase the number of human-caused ignitions. Harm to wildlife / ecosystems: Roadless areas provide habitat for an estimated 60% of the nation's vulnerable wildlife. The rescission would affect more than 7 million acres of critical habitat and put more than 300 protected species at risk: grizzly bears, Canada lynx, wolverines, spotted owls, and native fish. Roads are a huge barrier to habitat, and disrupt migration corridors / introduce sediment, invasive species, and disturbance into some of the only remaining wild landscapes left. For wide-ranging species like grizzly bears, that disconnect can be the difference between a viable and a declining population. I’ve experienced grizzlies and wolves in their natural habitats, how could I not be a fierce advocate for them? Threats to drinking water. The protected areas supply drinking water to 20–25 million people. Forest soils and root systems filter contaminants naturally, reducing the cost and chemical burden of treating that water before it reaches taps. Road construction and logging are major drivers of sediment and chemical runoff in headwater streams. Rolling back these protections risks degrading water quality at the source for millions of downstream communities.There is no excuse for risking water quality for this many Americans. The cost of new roads. This proposal is fiscally hard to justify. The Forest Service already manages more than 380,000 miles of road, and has a maintenance backlog between $7 billion and $10 billion on the roads it already has. The agency hardly receives enough financing to maintain its existing network. Building new roads into roadless areas only adds to the unfunded liability. This holds taxpayers hostage to infrastructure the Forest Service has demonstrated it cannot afford to maintain. Indigenous impact and opposition. Tribal nations have clearly and consistently opposed this rescission. Dozens of Tribes submitted formal comments and requested consultation during the initial comment period and USDA acknowledges that most Tribes consulted oppose the repeal. Roadless areas often overlap with lands of deep cultural, spiritual, and subsistence significance. These are hunting and fishing grounds, sacred sites, and traditional gathering areas stewarded by Tribes for generations. The National Congress of American Indians passed a resolution supporting retention of the rule. Does that opposition not deserve to be weighed heavily? A better path forward? If the genuine goal is wildfire resilience and forest health, there are more targeted, less destructive tools available. The current Roadless Rule already permits road construction for public health and safety needs, and it does not block fuels reduction, prescribed burns, or other active forest work. I encourage USDA to instead invest in: (1) prescribed burning and mechanical thinning focused on the wildland-urban interface, protecting communities at risk; (2) fully funding existing road maintenance before creating new liabilities; and (3) continued, good-faith consultation with Tribal nations on management of these lands. I urge you to take this comment and those of my peers with similar comments to heart. The health of our environment, wildlife, and resources is counting on you to make the right choice. Sincerely, Megan Mitchell

My name is Richard Mitchell, I live in Coconino County in Flagstaff, AZ, right up against the Coconino National Forest. I firmly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. This rule has protected roughly 58.5 million acres of national forest for twenty five years from new road construction and commercial logging. That’s nearly a third of the entire National Forest System. Repealing it would open an estimated 45 million acres to development and logging (which is similar in size to the state of Washington). I recreate on this land throughout the country. Frequently. From my own backyard around the Coconino forest, to dispersed camping in Utah, hiking in Washington, backpacking in Colorado, and soaking in hot springs in New Mexico, I find therapy and refuge in these spaces. Friends I know fill their freezers for their families through hunting in these areas. And my native siblings strongly oppose this proposal out of principle and respect for their culture and roots. Repealing the Roadless Rule would make my life considerably worse and I am quite upset and appalled at this continual threat to the land that We The People have a right to. Highlighted below are the main reasons why I disagree with repealing the act, along with evidence-based information. Increased wildfire risk: This repeal has been framed as a wildfire-safety measure, but the evidence does not support that claim. The vast majority of wildfires in the United States are started by people, with over 90% of fires starting within half a mile of a road. Research from the Pacific Biodiversity Institute and more recent analysis from The Wilderness Society covering 1992–2024 shows that roads bring more vehicles, more campfires, more equipment sparks, and more human traffic into forests that are currently among the least fire-prone in the system precisely because they are hard to reach. Opening these areas to road-building will very likely increase the number of human-caused ignitions. Harm to wildlife and ecosystems: Roadless areas make up only about 2% of land in the lower 48 states but they provide habitat for an estimated 60% of the nation's vulnerable terrestrial wildlife. This rescission would affect more than 7 million acres of critical habitat and put more than 300 protected species at risk. Roads are a huge blockage to habitat, disrupt migration corridors, introduce sediment, invasive species, and cause disturbance into some of the only remaining wild landscapes we have left. Threats to drinking water: National forests are the single largest source of municipal drinking water in the country, supplying an estimated 60 million people across 33 states, with roughly 20–25 million people relying specifically on water that originates in currently protected roadless areas. Rolling back these protections risks degrading water quality at the source for millions of downstream communities that have no comparable substitute for these watersheds. The cost of new roads: This proposal is also fiscally hard to justify. The Forest Service already manages more than 380,000 miles of road — enough to circle the globe over fifteen times — and carries a maintenance backlog estimated between $7 billion and $10 billion on the roads it already has. The agency currently receives only a fraction of the annual funding needed to maintain its existing network. Building new roads into roadless areas would add to that unfunded liability rather than relieve it. Indigenous impact and opposition: Tribal nations have been clear and consistent in their opposition to this rescission. Dozens of Tribes submitted formal comments and requested consultation during the initial comment period, and USDA's own tribal summary materials acknowledge that most Tribes consulted oppose the repeal. Roadless areas often overlap with lands of deep cultural, spiritual, and subsistence significance. A better path forward? If the Department's genuine goal is wildfire resilience and forest health, there are more targeted, less destructive tools already available. The current Roadless Rule already permits road construction for public health and safety needs, and it does not block fuel reduction, prescribed burns, or other active forest-health work. I would encourage USDA to instead invest in: (1) prescribed burning and mechanical thinning focused on the wildland-urban interface, where it does the most good for actual communities at risk; (2) fully funding the existing road maintenance backlog before creating new liabilities; and (3) continued, good-faith consultation with Tribal nations on management of these lands, rather than a blanket nationwide repeal. I urge you to take this comment and those of my peers submitting similar comments to heart. The health of our environment, wildlife, and resources is counting on you to make the right choice. Sincerely, Richard Mitchell

Hello, As a wildlife biologist frequently tasked with evaluating short- and long-term impacts of development, I strongly oppose rescission of the roadless rule. Among many other benefits, roadless rule minimizes forest fire risk in these beloved areas. According to a 2026 study, the vast majority of human-caused fires (per 1,000 ha) occurred within 0-250 meters from a road. Under the proposed alternatives 2 and 3 (full rescission and modified rescission) ALL lands protected in my home forest, Coconino National Forest (and neighboring Prescott NF), would lose protection. The Coconino National Forest presently allows logging on millions of acres and opening roadless areas on the Coconino NF is unnecessary and irresponsible. I strongly urge USDA to reevaluate impacts of rescinding the roadless rule, as it is clear that the agency has not correctly estimated impacts. Alternative 1- No Action- is the only responsible option.