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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Living in Arizona, I value the ability to hike in remote areas without roads. The Oracle Roadless Area, the Butterfly Roadless Area, the Santa Rita area, and really any roadless corner of the Coronado National Forest matters to me. These lands are national treasures, not a holding area for money making. I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The Coronado holds 23 inventoried roadless areas totaling 482,687 acres. Those areas, spanning the Santa Ritas, the Rincons, and the other sky island ranges, are the connective tissue between isolated mountain forests surrounded by hot desert. Jaguars have been documented crossing from Mexico through the Santa Ritas into the Rincon Mountains and beyond, using the roadless corridors between those ranges as the only pathways that make that movement viable. The Upper Rincon Roadless Area, the Santa Rita area at 6,078 acres, the Happy Valley area at 7,972 acres: these are not abstract inventory entries. They are the ground where that connectivity either holds or breaks. Opening them to new roads does not protect them. It fragments them. I ask the agency to explain on the record why it believes the rescission is consistent with its own documentation of these corridors as irreplaceable biological pathways. 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 proposal cites wildfire management as a justification for rescission. That argument moves in the opposite direction from the agency's own findings. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask the agency to reconcile the rescission with those ignition figures and explain the departure from its prior findings. The proposal also rests on economic and employment grounds. The agency's own 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 to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. It makes no sense at all to build new roads when the agency cannot even maintain the current roads. The existing maintenance backlog stands at $6.9 billion against a road budget of about $73 million a year. The agency must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already collapsing under that backlog. The agency's own record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The proposal argues that state-specific approaches can replace the national rule. That argument has been tested. The Ninth Circuit found that local decision-making can incrementally reduce nationally significant roadless values, and the state-by-state replacement was rejected. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres, and across the Southwestern region 739 municipal water intakes sit in watersheds containing affected roadless areas. What happens to those values under a patchwork approach is not a hypothetical. The agency must explain how this proposal avoids the deficiencies the Ninth Circuit identified when the national rule was last replaced with a state-by-state approach. Finally, the agency's record states: "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 proposal argues that the 2001 rule exceeded statutory authority. The Tenth Circuit held that the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency owes a clear explanation of the legal basis for any position contrary to that holding, and it must provide one. Sincerely, Andrea C. Tucson, AZ

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Chiricahuas offer peaceful solitude, and the Santa Ritas feel like a whole other world, so close to Tucson yet entirely apart from it. I hike the Santa Rita Mountains frequently, looking for birds like elegant trogons found only in the sky islands of Arizona. These are not generic public lands to me. They are the reason I go outside. Rescinding the 2001 Roadless Area Conservation Rule would damage exactly what I am looking for when I go there, and this comment asks the agency to answer, specifically, for what its own documents already say. The Coronado National Forest holds 23 inventoried roadless areas totaling 482,687 acres, spanning the Santa Ritas, Chiricahuas, Galiuros, and Rincons, the connective tissue between the sky island ranges. Each range is an island of cool forest in a sea of hot desert. The birds I look for depend on that structure. The DEIS cites the finding 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. (Kroeger et al. 2022; McClure et al. 2013; Ware et al.) That is what the agency's own cited science says will happen to the habitat I walk through in the Santa Ritas. What I want to know is why that finding appears in the document and then disappears, with no projection of what it means for bird populations across the affected areas, and I ask the agency to address that gap directly. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range appears once and is then set aside. No projection across the 40.1 million acres of potentially affected environment follows from it. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres. The trogons I hike to see, the jaguars documented crossing from Mexico through the Santa Ritas into the Rincon Mountains and beyond, the verified species of the Coronado sky islands including Mexican spotted owl, Gould's turkey, Arizona treefrog, and ocelot: all of them live within a landscape whose integrity is measured partly by that fragmentation range. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and explain what that means for the species already documented there. The agency's own biological assessment does not soften its conclusion. "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats. That is the agency's own count, from the agency's own assessment. The proposal identifies mitigation for none of it. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule is issued. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. That number is stated and then left alone. No analysis of what harvest and roading would release under each alternative follows from it. Our public lands should be managed for wildlife, habitat, and responsible recreation, and none of those purposes is served by a document that cites a carbon figure of that scale and then draws no conclusions from it. The agency should quantify the change in carbon storage and sequestration under each alternative. The Santa Ritas are special because they are still intact. That is not sentiment; it is what the agency's own cited science describes when it documents the relationship between roads, noise, fragmentation, and biological loss. I am asking the agency to follow its own evidence to its own conclusions before it acts. Sincerely, Alex Patia Tucson, AZ

To the USDA Roadless Rule Rulemaking Team: As someone who spends time in the natural parts of this land, for both mental health, and science education for the high school students I work with and mentor- it is imperative that I talk to you about how our way of life, and the animals and land we protect would all be altered for ourselves and future generations. Short-sighted profit-seeking behavior, that which drives this proposed rescission of this rule, weighs very little against the real impacts on our world, and on life. This was the first place I went hiking when I came to Tucson, Arizona. I mentor students at a local high school, all whom love this area and know it to be a unique area on our sky island, a mountain long established as sacred to our indigenous people of this land. This trail has given me the gift of natural beauty, but most importantly, provided a home for many, and must be maintained. Being immersed in this land and part of this place brings us back to who we really are, and what we are meant to connect to. So many humans forget their place in this world, their connection to the earth. The roadless rule allows these sacred places to exist, allows us to remember ourselves. More importantly, it uplifts other species and wildlife, and protects forests and undisturbed soils that act as vital carbon storage, combating climate change. Roadless areas are key components of healthy, intact landscapes that drive outdoor recreation economies across the country. Developing and degrading these roadless lands with new roads and resource extraction will degrade these ecosystem benefits and cost the public dearly. Roadless areas are worth far more when left intact and undeveloped, and will cost the taxpayers so much. Beyond cost to our taxpayer dollars, there is an inevitable impact on humanity and wildlife ecosystems. I CHOOSE A NO ACTION ALTERNATIVE Regarding the Butterfly Roadless Area in the Coronado National Forest, Arizona: Hydrological Disruption and Invasive Species Establishment — Road construction requires fill material, culverts, and drainage modifications that alter the natural flow of water through the landscape. In the Butterfly Peak Research Natural Area and riparian zones, these changes disrupt the seepage and groundwater conditions that sustain federally endangered Arizona eryngo and Huachuca water-umbel. Simultaneously, the disturbed soil and compacted roadbed create ideal conditions for invasive grasses—buffelgrass, red brome, and Mediterranean grass—which are already documented as threats in the Coronado National Forest. These invasives establish along road corridors and alter fire regimes, increasing the risk of uncharacteristic wildfires that would destroy the mixed conifer and riparian forest habitat that supports both the spotted owl and the area's endemic plants. Without roadless protections, the Butterfly Roadless Area IRA becomes available for road building, timber sales, and motorized recreational access. These activities alter hydrology, fragment habitat corridors, introduce edge effects, and increase human disturbance — all of which may affect Loach Minnow (Tiaroga cobitis, E). The formal consultation obligation for Loach Minnow (Tiaroga cobitis, E) in the Butterfly Roadless Area IRA, Coronado National Forest, is species-specific. The agency cannot satisfy it through a generic programmatic consultation or a blanket finding covering all listed species across all roadless areas. Each species in each area requires its own consultation finding and its own determination of effect. "Construction of roads, utility corridors and other human infrastructure kills any sessile or slow-moving animal and all vegetation in the path of the feature. Roads and other linear infrastructure negatively impact wildlife through increased mortality, decreased habitat amount and quality, changing species movement patterns, and fragmentation of populations into smaller subpopulations, which are more vulnerable to local extinction." — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing Trombulak and Frissell 2000, 2000 I urge the Secretary to decline this rescission and preserve the existing roadless area protections. With kind regards, Rachel Mueller CommentID: RLC-20261007-PR837Y

Dear Secretary Rollins and Chief Schultz: Can we be better at taking care of our stuff? Lived here and hiked all over these beautiful trails I helped my friend backpack across the Catalina mountains and have spent lots of time enjoying the beauty of this location Regarding the Catalina St. Pk. Roadless Area in the Coronado National Forest, Arizona: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Roadless areas function as intact reference landscapes. Roadless areas retain levels of ecological integrity that roaded landscapes have lost. Watersheds with the highest ecological integrity scores tend to have high proportions of roadless or wilderness area (over 50 percent); watersheds with the lowest integrity tend to have low proportions of roadless area and high proportions of moderate-density roads (USDA Forest Service 2000; Talty et al. 2020). — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf); Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288) Rescinding the Roadless Rule would open the Catalina St. Pk. Roadless Area, Coronado National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. These areas allow us to preserve our forests. Extended habitat allows the ecosystem to thrive My position hasn't changed: keep the Rule. Earnestly, CommentID: RLC-20261006-DSZLXO

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule and urge the U.S. Department of Agriculture to adopt the “No Action” alternative. I am an avid user of our National Forests and a registered Trail Steward in Coconino County, Arizona of the Arizona Trail. The Arizona Trail is a National Scenic Trail that runs the length of the state of Arizona. Our undeveloped public lands are among our nations most valuable natural resources. The Roadless areas provide recreation opportunities, wildlife habitat and protect our watersheds. Once we develop these spaces, we can never get them back. The Arizona Trail specifically crosses areas throughout the state that would be affected by any change the Roadless rules. Area's of the Coronado National Forest near Tucson would be directly impacted and damaged. Our national lands should be managed for long-term public interest instead of short-term business opportunities. Fully or partially rescinding the Road Rule under Alternative 2 and 3 would be a mistake that will hurt every generation to come. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action Alternative.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The sky islands of the Coronado National Forest are already being squeezed from every direction. I hike in the Coronado and in the national forests of Utah, Northern Arizona, and Oregon, and what draws me to those places is exactly what this proposal would put at risk: country that has no roads in it yet. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The Coronado holds 23 inventoried roadless areas totaling 482,687 acres. The Santa Ritas, Chiricahuas, Galiuros, and Rincons are sky islands, each one a cool forest standing in a sea of hot desert, and the roadless corridors between them are the only pathways that make movement across that landscape viable. Jaguars have been documented crossing from Mexico through the Santa Ritas into the Rincon Mountains and beyond. That is the northernmost extent of jaguar range. Elegant trogon, Mexican spotted owl, Gould's turkey, Arizona treefrog, and ocelot depend on the same corridors. Roadless areas are rare, and only getting more rare. We should protect rare things that have value. A logged stand grows back; the agency's own analysis acknowledges that roads do not. The agency's cost accounting here does not add up. The proposed rule certifies no significant impact on small entities, yet the record beneath that certification tells a different story: "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 regulatory flexibility analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, not the outfitters and guides who actually hold permits in the affected areas, and then concedes some of those firms may lose those receipts. That is not a meaningful assessment. 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. The agency also invited comment on reliance and then did nothing with it. 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. My use of these forests, and my expectation that unroaded country will remain unroaded, is precisely the kind of reliance interest that solicitation called for. Under the legal standards that govern an agency changing course, those interests must be identified and weighed, not invited and ignored. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. The agency's own fire data argues against opening these areas. "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 effects analysis concedes that road access could increase the number and frequency of wildfires. If the stated justification for the proposal includes reducing wildfire hazard, the agency must quantify the expected increase in human-caused ignitions that new road access would bring and weigh it honestly against that claimed benefit. My tax money should not build new roads into country that has none, especially when the agency cannot maintain the roads it already has. Please do not use my tax money to build new roads. There are plenty as is, and they create long-term damage. The record confirms the problem: "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." Utah alone holds 222 inventoried roadless areas totaling 4,013,529 acres, and across the Intermountain region 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The DEIS states that road mileage, deferred maintenance, and management costs are likely to increase under the proposal. The agency must name the funding source for any new road construction and maintenance and state plainly what the projected change to the backlog would be. Sincerely, Levi Tenen Norfolk, VA (but native Arizonan)

I am submitting the comment regarding the proposed rescission of the 2001 Roadless Area Conservation Rule. The Coronado National Forest is my current closest national forest, and is the one that currently makes this a personal issue. I spend my time on public lands as a landscape photographer, particularly drawn to pine forests, mountain peak, changing light, and landscapes of the American West. Every once in a while, I am lucky enough to capture wildlife as well. While I’m out in the Coronado National Forest, I hope to see specials such as black bear, mountain lion, coatimundi, bobcat, and the countless bird species that make southeastern Arizona such a remarkable place. The possibility of encountering those animals and knowing that they can live with a degree of isolation is part of what makes these lands valuable to me. I also want to acknowledge something that I think is important to this discussion; I understand the argument for access. Public lands belong to the public, and I believe people should have meaningful opportunities to experience them. Roads can provide access for recreation, people with mobility limitations, emergency responders, firefighters, hunter, anglers, and land managers. I do not believe that every roadless area should be treated as untouchable under every circumstance. But I also do not believe that the answer to improving access is simply to build more roads into currently roadless areas. Road construction changes the character of a place. It can increase human activity, fragment habitat, create maintenance obligations, and introduce impacts that remain long after the original reason for constructing the road has disappeared. I believe the Forest Service should carefully weigh those permanent consequences against the specific public benefit a proposed road would provide. I am also concerned about the wildfire rationale for rescinding the Roadless Rule. I understand the argument that roads can provide faster access for firefighters and that benefit should be considered. However, access has another side: more roads also mean more human activity in forests, and human activity is a significant source of wildfire ignitions. Recent research examining wildfire records across the National Forest System from 1992 to 2024 found that wildfire ignition density was substantially higher near roads than in more remote areas. The study found that lands within 50 meters of roads had the highest ignition density, while inventoried roadless areas had much lower ignition density. I believe the complex relationship between roads and wildfires needs to be looked at carefully when determining when and where to build a road. I am similarly concerned about opening current roadless public lands to increased resource extraction and particularly mining. I recognize that mining provides important resources for our county and that responsible resource development has a place in public-land management, but the environmental consequences of some mining operations can last for generations. Once example that has stayed with me is the Berkeley Pit in Butte, Montana. I lived in Butte for 13 years, and have seen firsthand how dramatically mining can alter the landscape. The pit and surrounding historic district are now part of a large superfund site. EPA documents describe widespread contamination of the area from historic mining and milling. The citizens are constantly having to fight for continued treatment, monitoring and cleanup decades after the mining activity that created many of those problems has ended. I do not believe this to be an argument against mining, but rather an argument for responsible resource development and accountability for restoring the land afterwards. Most importantly, I believe we need to remember what public lands are. They are not simply resources belonging to the current generation to use as we see fit. They are public lands held in trust for generations of Americans who have not been born yet. I may or may not have children of my own, but that does not change how I think about this. The people who will use these forests fifty, one hundred, or two hundred years form now deserve to inherit more than whatever we decide is economically useful today. We are temporary stewards. Our responsibility should be to leave these lands in at least as good a condition as we inherited them, and whenever possible, better. I respectfully ask the Forest Service to retain meaningful protections for inventoried roadless areas and to manage these lands with the long-term interests of the American public, and future generations in mind.

I am a clinical herbalist and poet, and I live and work near the Coronado National Forest. I am writing to urge you to retain the 2001 Roadless Rule and to reject the proposed full rescission. Roadless forests are the source of my work and of my community's water. Many medicinal plants depend on cool, shaded, undisturbed ground, and they decline when habitat is fragmented by roads, which also bring invasive species, soil disturbance, and heavy harvesting pressure. Roadless areas also protect the headwaters of the streams and rivers that Arizona communities rely on. Keeping a watershed intact is far cheaper than replacing the filtration, flood control, and cool, clean flow it provides for free. Roads are a long-term liability the agency cannot afford. The Forest Service already struggles to maintain its existing road network of roughly 380,000 miles. Opening millions of additional acres to road construction adds obligations the agency has not shown it can fund. It is like adding rooms to a house whose roof is already leaking. Roads do not clearly serve wildfire safety. The stated justification is fire prevention, but human-caused ignitions concentrate along roads, and roads spread invasive grasses that carry fire. If the goal is protecting communities, the effective work happens in the zones near homes, where the 2001 rule already allows thinning and fuel reduction. Removing the rule is like pulling a fuse because it keeps tripping, when the real fault is somewhere else in the circuit. The process has been inadequate for a decision this large. The proposal would affect tens of millions of acres, yet the public was given a 45-day comment window and no public hearings. The original rule was developed over years, with hundreds of public meetings and more than 1.6 million comments, overwhelmingly in favor. A change of this scale deserves at least that level of public engagement and meaningful tribal consultation. I respectfully ask that you (1) retain the 2001 Roadless Rule, (2) extend the comment period and hold public hearings, and (3) give full consideration to the Tribal and conservation-based alternatives submitted in this docket. Thank you for considering my comment. Kimberly Kling Hereford, AZ

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I have spent time across every National Forest in Arizona, and each one has given me unforgettable experiences. I grew up in the forests, lakes, and rivers of Minnesota, and I credit that landscape as my conservation spark. These places sustain my wellbeing. I am a conservation scientist, with a degree in Conservation Biology and Ecology with a minor in Sustainability. The threats that rescinding the Roadless Area Conservation Rule would create are not up for debate in the scientific community. I oppose this proposal without reservation. The agency's own record on fire should end the wildfire argument for rescission before it begins. 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." I ask that the agency explain how the proposal departs from that finding, and that it reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case is no stronger. The agency's own record concedes that "the total timber volume affected by this rule is less than 0.5% of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4% of the current national production." Against projected timber revenue to the Forest Service of $5.2 to $11.4 million a year, the agency's own Cost Benefit Analysis projects recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. That range cannot establish a net benefit. Meanwhile, the agency already carries a $6.9 billion maintenance backlog on its existing road system against a road budget of roughly $73 million a year. Building new roads into new and difficult terrain will only deepen that hole. There is nothing to gain and everything to lose here. I ask that the agency reconcile the proposal with those numbers and explain how it justifies expanding a road network already collapsing under deferred maintenance. The Coronado National Forest holds 23 inventoried roadless areas totaling 482,687 acres spanning across southern Arizona. These sky islands and the roadless corridors between them are the connective tissue that makes the whole system function. Mexican spotted owl, Gould’s turkey, Arizona tree frog, and ocelot also depend on these intact areas. The DEIS itself 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% of species avoiding the noise entirely. Fragmentation does not just inconvenience visitors. It unravels the ecosystems that make the wildlife present in the first place. I ask that the agency address specifically how it weighs those documented impacts to bird communities and sky island connectivity against the marginal resource extraction values its own analysis could not confidently net positive. On water: preserving what clean water sources we have left is imperative right now. As climate change causes unpredictable shifts in our global system and water demands heighten by data centers and other infrastructure, robust ecosystems that protect water sources matter more, not less. The agency's own analysis says roads and their facilities can produce up to 90% of the sediment from a timber sale. The agency must address what rescission means for watershed integrity, and it must do so with specificity, not generality. The proposal argues that state-by-state approaches can substitute for a national rule. The agency's own record answers that: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The 9th Circuit has already reviewed what happens when the agency replaces the national rule with state petitions, and it went poorly. The agency must explain how this proposal avoids those same deficiencies. On authority, the 10th Circuit has already ruled: "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 and state plainly the basis for any contrary legal position it now intends to advance. We are at a moment when we desperately need to foster connection and stewardship with this quickly changing world. Rescinding the Roadless Rule moves in exactly the wrong direction. I urge the agency to withdraw this proposal. Sincerely, Emma Rubin Glendale, AZ

I am a field biologist who regularly works on national forests containing inventoried roadless areas in California that would be impacted from the rescission of the 2001 Roadless Rule including: Stanislaus NF, Sierra NF, Plumas NF, and Mendocino NF. I also regularly visit Coronado NF lands containing inventoried roadless areas in Arizona, including the Chiricahua Mountains, Dragoon Mountains, Santa Rita Mountains, and Catalina Mountains. These lands and the communities that inhabit and rely on them, some of which are threatened and endangered species, are sensitive to further fragmentation and degradation from development. Their watersheds (which humans also rely on) are sensitive to the erosion and sedimentation caused by construction and maintenance of new roads and/or other development. I strongly oppose the recission of the Rule and list objections to the rationale for the Proposal and to the draft EIS below. One of the main stated rationales for rescission of the Rule presented in the Proposal is the need to return control of inventoried roadless areas to local FS authorities because the national 2001 Roadless Rule was too restrictive and burdensome to locally adapt, specifically regarding active management for fire and fuels. Yet, on page 14 of the draft EIS, Table 1., 2001 Roadless Rule exceptions (alternative 1) (36 CFR 294.12(b) and 294.13(b) (2001)), states: “Road construction, reconstruction, including temporary road construction, is prohibited in inventoried roadless areas, except when: 1) A road is needed to protect public health and safety in cases of an imminent threat of flood, fire, or other catastrophic event that, without intervention, would cause the loss of life or property” Fuel reduction projects on FS lands in California have been actively taking place since the Roadless Rule went into effect. I know this because I have worked on these projects. I also know this because there is published research documenting these activities: “The findings in our analysis are consistent with other studies, including research supported by the Forest Service’s Rocky Mountain Research Station, which evaluated nearly twenty years of monitoring data, concluding that “a lack of roads in IRAs [Inventoried Roadless Areas] has neither prevented fuel treatment nor led to substantially more fire” (Trout Unlimited 2026). On page 24 of the draft EIS, Table 3., which shows comparison of effects under alternatives 1-3 divided by resource/topic, under Fire and Fuels Management, it states “Currently, the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands. Under alternatives 2 and 3, if there is an increase in public road access, there could be increase the number and frequency of wildfires as human-ignitions are more likely near roads.” This statement, along with statistics from other published, peer-reviewed, and agency-accepted studies regarding the topic (see below), refute the argument that adding additional roads would reduce fire risk by any meaningful amount. “Analysis of information about ignition source and location from the Forest Service fire occurrence dataset (USA.FireOccurrence) shows the occurrence of human-caused wildfire ignitions is strongly correlated with roads. Seventy-eight percent of human-caused fires on NFS lands nationwide start within ½ mile of a road” (Trout Unlimited 2026). References: Trout Unlimited, 2026. Roadless: Active Management and Fire A GIS data analysis and research review. September 2, 2026. Accessed October 5, 2026, online at https://storymaps.arcgis.com/stories/3aecb3a57df8494d8c74582686feaefa.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The reasons being given for rescinding the Roadless Rule are obviously disingenuous. It's clear to me that the real purpose is to open our forests to logging, mining, and other industry. Arguing in good faith with a proposal that has not been made in good faith may be futile. Nevertheless, I write to register my objection, given that what stands to be destroyed is utterly irreplaceable. The Chiricahua roadless area in the Coronado National Forest is one of the places I care about most. The Coronado holds 23 inventoried roadless areas totaling 482,687 acres. Those acres are not simply forest. They are corridors connecting the sky islands of southern Arizona, each range a cool island rising from hot desert, and the roadless land between them is what keeps that network functional. Jaguars have been documented crossing from Mexico through the Santa Ritas into the Rincon Mountains and beyond. That crossing depends on the roadless corridors being intact. The Chiricahuas, the Galiuros, the Rincons, the Santa Ritas, these are not interchangeable parcels. They are the northernmost extent of jaguar range. Elegant trogon, Mexican spotted owl, Gould's turkey, Arizona treefrog, ocelot, these species persist here because the connective tissue has not been cut. I am asking the agency to reverse course on the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The agency's own environmental record undermines the wildfire rationale offered for this rescission. 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." That is the agency's own finding. The DEIS also reports human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that human-caused ignitions increase in abundance with proximity to roads. The proposal uses wildfire management as a justification for opening these areas to roads, and the agency's own data runs directly contrary to that logic. I ask that the agency explain why the proposal departs from these findings, reconcile the rescission with the ignition data in DEIS Table 21, and quantify the expected increase in human-caused ignitions that new road access would produce before weighing it against any claimed reduction in wildfire hazard. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres. Across the Southwestern region, 739 municipal water intakes sit in watersheds containing affected roadless areas. The economic consequences of degrading those watersheds fall on real communities. Yet the regulatory flexibility analysis accompanying this proposal reaches a no-significant-impact conclusion by spreading losses across every small firm in the sector nationally, rather than examining the outfitters, guides, and tour operators actually holding permits in the areas at stake. The DEIS itself names those operators as affected parties, and the agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. Spreading that loss across a national average conceals the concentrated harm on the small businesses actually operating in these forests. The agency must withdraw its small-entity certification and assess the impacts on the firms that hold permits inside the potentially affected roadless areas, not on a statistical average firm with no presence there. The proposal also 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. This comment is one such reliance interest. The 2001 rule has shaped how conservationists, recreationists, and communities have understood and planned around these landscapes for more than two decades. An agency reversing a rule of that duration and reach is required to identify and weigh the reliance its prior policy created. Soliciting those interests in the Federal Register while declining to assess them in the supporting analysis is not a response, it is a record gap. The agency should account for the reliance interests described in the comments it receives, including this one, before any final action is taken. The Chiricahua area and the broader Coronado sky island system represent something that cannot be rebuilt once the corridors are broken. I urge the agency to retain the 2001 Roadless Area Conservation Rule in full. Sincerely, Candice Green Tucson, AZ

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I urge USDA to withdraw it and adopt the No Action alternative. The preamble's own findings do not support the stated purpose and need, and the record fails to analyze costs the agency itself acknowledges. I live in Arizona and Vermont, and have seen firsthand the ecological and economic benefits of the rule. In addition to using public lands for recreation, these lands protect our nation's heritage, and natural resources we will rely on into the future. As Arizona is currently in a water crisis due to decreased Colorado River flows, intact national forests that ensure clean water supply and aquifer recharge are essential--and any change to this rule can be read as disrespect for the citizens of that state. Near Tucson, where I live, the The Upper Rincon and Santa Rita IRAs on the Coronado National Forest protect sky island headwaters above the Tucson basin, and the Arizona National Scenic Trail crosses both. USDA should analyze the rescission's effects on these watersheds and on recreation along the trail. The agency's findings undercut its rationale. USDA justifies rescission by citing wildfire, insects, and forest health (91 FR 53828), yet concedes management opportunities would be "modest and localized" (53829). Projected timber gains assume harvest across all 4.8 million operable acres, which USDA calls "unlikely" (53829). Speculative benefits cannot rationally justify removing protections from tens of millions of acres. Under Motor Vehicle Mfrs. Ass'n v. State Farm (1983), the agency must show a rational connection between the facts found and the choice made. It has not. Drinking water impacts are unanalyzed. The preamble acknowledges roadless areas at high risk of intense fire that threatens "drinking water sources" (53829) and records Tribal concern for water quality (53832), but quantifies no effect of new roads, harvest, or leasable mineral development on sediment, turbidity, or treatment costs for downstream utilities. USDA should identify affected public water systems by watershed and quantify these effects before any final action. USDA admits the rule will raise human-caused ignition risk. The preamble states greater public access "can increase human-caused ignition potential" (53829). The fire benefit it cites, fuel treatment in the wildland-urban interface, involves 9.8 million acres, about 24 percent of affected areas (53829), and the 2001 Rule already permits cutting small-diameter timber to reduce uncharacteristic wildfire effects (36 CFR 294.13(b)(1)). A narrower alternative exists: clarify that exception for WUI fuels work while keeping protections elsewhere. USDA must explain why it rejected that option. Economic costs are understated and fall on small entities. USDA estimates $6.1 million per year in lost recreation benefits, plus closures, noise, user conflicts, and trade-offs for tourism (53829-30), and says impacts could exceed $100 million (53830). Outfitters, guides, and tourism operators are largely small businesses, yet USDA certifies no significant impact on small entities (53831). That certification conflicts with its own findings. New roads would also add to a $6.9 billion deferred maintenance backlog (53829) that the analysis does not cost out. Wildlife and subsistence analysis is incomplete. The preamble lists threatened and endangered species and plant and animal diversity among the values at stake (53828), notes possible long-term effects on commercial fisheries (53830), and defers ANILCA Section 810 subsistence hearings to a later notice (53830). Finalizing before that analysis is complete would be premature. Tribal consultation is incomplete. USDA concedes the rescission has substantial direct effects on Tribes, that most Tribes consulted oppose it, and that only 29 of 64 requested consultations have been held (53831-32). The final Tribal impact statement will appear only with the final rule. Proceeding first is inconsistent with E.O. 13175 and the federal trust responsibility. Reliance interests must be weighed. USDA invites comment on reliance interests (53830). Under DHS v. Regents (2020), an agency changing course must consider them. Water utilities, recreation businesses, Tribes, and communities have relied on these protections for 25 years. I request you withdraw the proposed rule and adopt No Action. The USDA justifications for changing this rule are contradicted within its own documents. This increases new fire risk, decreases water quality, and disproportionately affects the economies of smaller towns and rural America. This cannot be justified and cannot go through.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule, and I urge the Forest Service to reject both the full rescission and the partial modification alternative and retain the 2001 Rule in its entirety. I live in two states, spending different parts of the year in California and Arizona. I have a background in Environmental Science and work in corporate sustainability. I am also an amateur bird photographer and avid hiker. Rescinding the Roadless Rule will impact a number of public lands where I, and so many others, frequently recreate: the Apache-Sitgreaves, Coconino, Coronado, Kaibab, Prescott, and Tonto National Forests in Arizona, and the Inyo, Lassen, Sierra, Sequoia, Tahoe, and Shasta-Trinity National Forests in California. These are places where we camp, hike, fish, kayak, and filter water from lakes and rivers to drink. They are also where I see and photograph native and migratory birds. In the Coronado National Forest, I have photographed the Elegant Trogon and Montezuma Quail. In the Inyo National Forest, I have photographed the Greater Sage-Grouse. Species like these depend on large, intact, unfragmented habitat, which is exactly what roadless areas provide. Roads and the traffic and disturbance they bring are among the most significant threats to birds like these. Rescinding the rule removes protections for 45 million acres of the wildest and most intact public lands. The total land mass of the United States is approximately 2.2 billion acres, so 45 million acres represents only 2% of it. We do not need to open these areas to road construction, development, and commercial logging when so many other lands already support these activities. Opening these areas will harm the public and our ecosystems in the following ways: 1. Increased wildfire risk. The Department argues that the 2001 Rule has limited vegetation management and contributed to a lack of active management. That is not supported by the Rule itself. The Rule already allows the cutting of generally small-diameter timber to reduce the risk of uncharacteristic wildfire. It also allows road construction when needed to protect public health and safety from an imminent threat of fire, flood, or other catastrophic event. The fuel reduction work that most protects homes and communities is concentrated in the wildland-urban interface, not in remote backcountry far from any town. Meanwhile, new roads bring people and vehicles closer to dry vegetation and increase human-caused ignitions. Studies show that fires are 4x more likely to start near a road than in a roadless forest. Rescinding the Rule would not meaningfully improve the Forest Service's ability to fight fire. It would add new ignition sources to some of our most remote and hardest-to-reach forests. 2. Threats to clean drinking water. National forests are a major source of drinking water across the West, and roadless areas sit in many of the headwaters that feed the rivers and reservoirs our communities depend on. Roads are one of the leading sources of sediment pollution in forest streams. They erode, channel runoff, and deliver silt and contaminants directly into waterways. That degrades water quality for downstream communities and increases treatment costs for municipal water systems. It also affects people like me who filter water directly from backcountry lakes and streams. Protecting roadless headwaters is one of the most cost-effective ways to protect water supplies for tens of millions of people. 3. Loss of habitat and ecosystem resilience. Roads fragment habitat for sensitive species and degrade our most intact and resilient ecosystems. In my work in corporate sustainability, companies increasingly recognize the value of natural capital, including carbon storage, watershed protection, and biodiversity. These intact ecosystems deliver those benefits at no cost to taxpayers, and they represent only 2% of our land mass. They should be protected. 4. Increased taxpayer burden. The Forest Service already manages roughly 370,000 miles of roads and faces a multibillion-dollar deferred maintenance backlog. It lacks the staff and funding to maintain the roads it already has. Building more roads in roadless forests will only add to that backlog and shift more cost onto taxpayers. In addition to making taxpayers pay more, rescinding the Rule ignores the will of the American people. When the Clinton Administration first proposed the Roadless Rule in 2000, it received over 1.6 million public comments, more than any administrative proposal in U.S. history at the time. When the Trump Administration initially proposed rescinding the Roadless Rule last September, over 600,000 Americans submitted public comments, with over 99% urging that the Roadless Rule be retained. For these reasons, I urge the Forest Service to select the no-action alternative and keep the 2001 Roadless Area Conservation Rule in place.

As an Arizona resident living in the Chiricahua Mountains in the Coronado National Forest, I strongly oppose the U.S. Department of Agriculture’s proposal to repeal the Roadless Area Conservation Rule. The U.S. Forest Service first enacted this conservation rule in 2001. Roadless areas serve as biological strongholds for imperiled species, and recognizes that habitat fragmentation harms wildlife and that intact forests act as buffers against the spread of invasive plant species. The proposed rule contemplates an abundance of resources at the local level to assess the decision regarding road conditions if the Rule is repealed. Yet we know this is far from the truth - there will be no funding stream proposed or contemplated to support any serious consideration at the local level. The default position will be to allow road construction and commercial logging while compromising public safety and endangering wildlife and clean water. Additionally, expanding roads into forested landscapes will increase wildfire risk. Research has shown that human-caused ignitions are responsible for the vast majority of wildfires, and are roughly four times more likely to start near roads, due to causes like sparks from vehicles and unattended campfires. I urge the USDA to cease its efforts to repeal the Roadless Rule which will significantly harm the Coronado National Forest and other roadless forests. Please remember that Americans live in these forests and stop this repeal effort.

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.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Santa Rita Mountains of southern Arizona are where I learned to camp and backpack. I was born and raised in Arizona, and those mountains, along with the deserts surrounding them, shaped everything I understand about wild country. The sky islands of the Coronado National Forest, ranging across the Santa Ritas, Chiricahuas, Galiuros, and Rincons, are the connective tissue between some of the most biologically extraordinary landscapes on this continent. Each range is an island of cool forest in a sea of hot desert. The Coronado holds 23 inventoried roadless areas totaling 482,687 acres, and I am writing to oppose rescinding the protections that have kept them intact. The wildfire rationale offered for this rescission is the place I want to start, because the agency's own record contradicts it. The 2001 rule's environmental analysis 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." That finding was made on the basis of the agency's own data, and the draft environmental impact statement supporting the current proposal does nothing to repudiate it. The Santa Ritas are precisely the kind of high-value, fire-prone landscape that finding was meant to protect. I ask the agency 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, and explain why the proposal departs from findings its own staff put into the record. The economic case for rescission is equally unsupportable on its own numbers. The agency's 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 revenues that negligible, the agency's own 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, with a net present value ranging from -$92 million to +$199 million. The Forest Service is already carrying a $6.9 billion maintenance backlog on its existing road system. What justification exists for expanding that system when the agency cannot establish a net benefit from doing so? I ask the agency to answer that question directly and in writing before this rule moves forward. The legal authority question deserves the same directness. The proposal suggests the 2001 rule exceeded statutory authority. The Tenth Circuit addressed that argument and was unambiguous: "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." That court found the rule within the authority granted by the Organic Act and MUSYA and did not find it created de facto wilderness. I ask the agency to explain on the record what legal basis it believes supports a contrary reading, given that holding. The jaguars documented crossing from Mexico through the Santa Ritas into the Rincon Mountains represent the northernmost extent of jaguar range in North America. The roadless corridors between the sky islands are, by the agency's own verified record, the only pathways that make that range viable. Elegant trogon, Mexican spotted owl, Gould's turkey, Arizona treefrog, and ocelot depend on the same connected landscape. Opening these corridors to roads does not merely affect scenery. It severs biological pathways that took geological time to form. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres, and across the Southwestern region, 739 municipal water intakes sit in watersheds containing affected roadless areas. The cumulative stakes of this rescission extend well past the individual ranges I know best. Finally, the regulatory flexibility certification that accompanies this proposal cannot withstand scrutiny. The DEIS names outfitters, guides, and tour operators as entities affected by the action, and the agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The agency reached its no-significant-impact conclusion by distributing that loss across every small firm nationally rather than examining the businesses holding permits in the areas actually at risk. The agency must withdraw that certification and assess the impact on the small entities operating in the potentially affected roadless areas, not a national average that obscures the local reality. Sincerely, Brandi Martinez Chandler, AZ

October 3, 2026 Comments on the proposal to rescind the Roadless Area Conservation Rule. Docket # FS-2025-0001. My name is Suzanne DeVore and I live in Mosca, Colorado at zip code 81146. I am a voter. I am an avid hiker, walker, bicyclist, Nordic and downhill skier, camper and birder. I spend a ton of time every year recreating on public lands. It is my understanding that despite 99% public opposition to its rollback, the Administration moved forward with its intent to rescind the 2001 Roadless Rule by publishing a Draft Environmental Impact Statement (DEIS). I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I strongly support Alternative 1, the No Action alternative. I love spending time in the National Forests near where I live in southern Colorado. Including the Rio Grande National Forest, the San Juan National Forest, the Gunnison National Forest and the San Isabel National Forest. I am fortunate to be able to walk to the Sangre de Cristo Wilderness from my home. I also spend weeks camping in the neighboring state of Wyoming. I particularly love the Medicine Bow National Forest and the dramatic Snowy Range in southern Wyoming. I also love to camp in the Bighorn National Forest and backpack in the Wind River Range. My husband is an avid fly-fisherman, so this determines a lot of the places we visit! We like to travel to the Coronado National Forest in Arizona for hiking and cycling during the winter. We particularly love the areas in and around the Chiricahua mountains. This proposal is just ludicrous for many reasons, but mainly because the current road system is stressed now! The U.S. Forest Service lacks the capacity, in funds and workforce, to support its existing roads, much less an increased inventory of roads. There are plenty of roads now. Roads cause excessive erosion and siltation to streams. Most of America's clean, fresh watersheds start in national forests. In this time of changing climate and severe droughts the current rule protects our valuable drinking water. Roadless areas help keep invasive species at bay and prevent pollution. The DEIS details many points on this topic. The current rule protects intact ecosystems for American wildlife. Roadless areas provide habitat for vulnerable wildlife species, including the Canada Lynx in our area. These roadless landscapes, often adjacent to other protected areas, like wilderness, are critical for habitat connectivity and health. Roads severely impact birds and wildlife. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird variety and abundance. It is vital to avoid fragmentation of the roadless areas. The DEIS cites the finding that habitat fragmentation reduces biodiversity. Wildlife tend to disappear when forest cover thins; many avoid roads used by winter machines. The DEIS notes that wide-ranging mammals like the grizzly bear “have suffered habitat loss and the extirpation or fragmentation of their populations.” It is false that building more roads will help fight wildfires. Studies show that more roads do not lead to better forest health through increased fire-management activity. Conversely, Wildfire incidents happen near roads. Studies show that 90% of wildfires happen within 1/4 mile of roads. If more roads led to more fires, this action would increase the number of incidents, not improve response, as suggested. Our National Forests sustain some of our nation’s last stands of old growth forest. Here in Colorado our nearby Rio Grande National Forest and all the national forests across the United States are an economic boon for tourism and for well-planned and regulated timber sales. No new roads are required to support these benefits of the forest. It is widely recognized that the purpose of changing the roadless rules has nothing to do with forest health as it is proclaimed to do. The purpose is to reduce regulatory burden and return decision making to local officials, not U.S. Forest Service experts with years of education and experience managing our forests for all U.S. citizens. This proposal is a callous, greedy attempt to provide access to our public lands for oil, mining, timber and other extractive industries! It’s sacrificing our forests to make a few wealthy elite people richer. It would bring short-sighted and short-term benefits to these few, while ruining long-term, irreplaceable lands that belong to all of us, the public. I completely oppose the proposal to rescind or alter the Roadless Rule, and strongly support Alternative 1, the No Action alternative. Suzanne DeVore 113 Spring Creek Drive Mosca, CO 81146

Public Comment Opposing the Proposed Rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001, RIN 0596-AD66) Dear Director, Ecosystem Management Coordination, I am writing to voice my firm opposition to the U.S. Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule. I advocate for the permanent preservation of all 44.7 million acres of Inventoried Roadless Areas (IRAs) nationwide. The current federal baseline ensures a unified, robust standard of ecological integrity that localized forest plans simply cannot replicate. While I care about the protection of all national forests across every state, this proposal strikes incredibly close to home. I live in Arizona, where I have hiked and backpacked through the Tonto National Forest and around Mount Lemmon in the Coronado National Forest numerous times. I know firsthand how vital these unroaded spaces are to preserving the delicate desert-to-mountain ecosystems, protecting local municipal watersheds, and offering wild landscapes for quiet recreation. If the Roadless Rule is rescinded, the iconic backdrops of the Arizona National Scenic Trail which winds directly through IRAs in these forests could be forever scarred by industrial road construction and commercial logging. Furthermore, my personal connection to our national forests spans the country. I have had the privilege of creating beautiful memories hiking in the Deschutes National Forest in Oregon, the George Washington National Forest in Virginia, and public lands near Ogden, Utah. Most deeply, I proposed to the love of my life in the Snoqualmie National Forest in Washington. These are not merely administrative parcels of land to be exploited; they are the irreplaceable geography of our lives. The impacts of this rescission also extend directly to my loved ones. I have family and friends who rely on the intact backcountries of Washington and Montana for hiking, hunting, and fishing. Millions of outdoor enthusiasts depend on the primitive habitats protected by the 2001 Rule to maintain healthy big game populations and native trout streams. I strongly reject the agency's primary justification that rescission is required for localized forest management, and I urge you to consider the following substantive points regarding wildfire and watershed degradation: - Increased Wildfire Risk and Human-Caused Ignitions: The Forest Service's own DEIS data confirms that repealing the 2001 Roadless Rule actually increases the probability and frequency of wildfire ignitions. Historically, inventoried roadless tracts have up to four times fewer wildfire starts than heavily roaded forest areas. Carving new road networks into remote backcountry provides vehicle access that introduces a primary source of human-caused ignitions. Furthermore, commercial logging operations open up the canopy, altering local microclimates by drying out understory vegetation, creating wind tunnels that accelerate fire spread, and introducing highly combustible fine fuels. - Severe Degradation of Watersheds and Drinking Water Resources: Roadless areas safeguard the headwaters of vital municipal watersheds that provide clean, unfiltered drinking water to over 25 to 60 million Americans. Roads inherently disrupt natural hydrology. Constructing new roads, culverts, and stream crossings triggers severe soil erosion and mass wasting events. The resulting sedimentation and toxic runoff empty directly into pristine headwater streams, choking aquatic habitats, decimating native trout and salmon spawning grounds, and threatening down-river municipal water supplies. This structural damage will force local communities to bear millions of dollars in skyrocketing water treatment and infrastructure costs. The Forest Service already possesses the administrative flexibility under the 2001 Rule to execute targeted hazardous fuel reductions and handle emergencies without stripping protection from 44.7 million acres of pristine public land. Adding more roads when the agency already faces an $8.6 billion deferred road maintenance backlog is environmentally and fiscally irresponsible. Our national forests are an interconnected legacy belonging to all Americans and future generations. I urge the U.S. Forest Service to reject the proposed rescission and maintain the 2001 Roadless Area Conservation Rule in its entirety. Sincerely, James Le Gilbert, AZ 85296

I strongly oppose rescinding the 2001 Roadless Rule. As a Tucson resident who spends much of my time hiking, trail running, mountain biking, climbing, and exploring Southern Arizona, I deeply value the wild lands protected by this rule. The Coronado National Forest’s roadless areas—including the Catalinas, Rincons, Santa Ritas, Whetstones, Cochise Stronghold, and Chiricahuas—are not just empty acres on a map. They are places where people experience wildlife, solitude, clean air, dark skies, and landscapes that remain largely wild. Removing these protections could open millions of acres to increased road construction and development, permanently changing places that cannot be replaced once fragmented. We can address wildfire and forest health without sacrificing some of Arizona’s most treasured wild landscapes. Please retain the 2001 Roadless Rule and protect these lands for future generations.

Please don’t rescind the roadless rule. These last tracts of old growth forest need to be protected for our children and their children's children. If they are destroyed, they are gone forever. These trees, this wilderness are part of the lungs of the planet. Along with protected areas in Canada, Patagonia, and other countries, they breathe in carbon dioxide and breathe out oxygen. They create a home for countless wild creatures: birds, bears, wolves, snakes, otters, marmots, bats, deer, cougar, fox, coyote, turtle, and badger. As many as 414 animals and plants listed as endangered, threatened or proposed for listing under the Endangered Species Act have ranges that overlap with roadless areas. Sierra Nevada Red Fox (Vulpes vulpes necator) The Sierra Nevada red fox is one of North America’s most endangered mammals, enduring in the high, snowy mountains of Oregon and California. Most often, this rare fox quietly pads through the snow-covered highlands undetected. However, without proper habitat protection, it could quietly disappear altogether. The numbers are dire: fewer than 40 individuals remain in the Sierra Nevada portion of its range, with the total population likely to number in the hundreds at most. Because Sierra Nevada red foxes are now so rare, direct sightings are incredibly unusual. Instead, biologists document their presence indirectly through game cameras and scat detection . Such “sightings” are often on remote, mountainous federal lands, including the Lassen, Stanislaus, Deschutes, and Mt. Hood National Forests. Relictual Slender Salamander (Batrachoseps relictus) No bigger than a crayon, the relictual slender salamander is considered a “microendemic” species—one that only exists in an extremely small range. Its habitat occurs on a single mountaintop in the southern Sierra Nevada of California. Over half its suitable habitat is protected by the Mill Creek Inventoried Roadless Area within the Sequoia National Forest. The U.S. Fish and Wildlife Service identified habitat degradation associated with road construction as a primary threat to the species’ continued persistence. Given this precariousness, it is unsurprising that the relictual slender salamander is proposed for listing as federally endangered. Rescission of the Roadless Rule could obliterate the little remaining intact habitat it has left. Grizzly Bears Ultimately, the recovery of grizzly bears depends on connectivity. Roadless areas function as “stepping stones,” allowing individuals to move between isolated recovery zones and recolonize historic habitats. Without the protection of the Roadless Rule, the natural expansion of the grizzly bear will become considerably more challenging. Jaguar (Panthera onca) The Chiricahua Roadless Area, located within the Coronado National Forest in southeast Arizona, is a hot spot for biodiversity. It contains suitable habitat for 57 at-risk wildlife, including the endangered jaguar. The Chiricahua Mountains, spanning roughly 700 square miles, serve as the home range for a specific male jaguar known to researchers as “ Jaguar #3 .” Students in Tucson have nicknamed the cat “Sombra,” Spanish for “shadow.” This individual was first detected in 2016 and has been photographed about 50 times since. The Chiricahua Mountains serve as an important dispersal corridor for jaguars like Sombra, moving north from core breeding populations in Mexico into the United States. Recovering the endangered jaguar requires conservation of its remaining habitat. Roadless areas in the borderlands are essential for facilitating safe wildlife movement across the landscape and for supporting the re-establishment of jaguars in the American Southwest.  Canada Lynx (Lynx canadensis) Over two million acres of lynx critical habitat are currently protected by the Roadless Rule. Thanks to protected lands like these, the U.S. Fish and Wildlife Service found that “current regional effects of timber harvest and thinning appear to occur at levels that are not likely threatening western lynx populations.” Removing roadless protections will increase threats to lynx, allowing more logging and development in their habitat. Southern Appalachian Brook Trout (Salvelinus fontinalis) There are currently more than 600,000 acres of roadless areas in the South.These areas provide prime fish habitat free from logging, roads and culvert barriers. For example, most brook trout streams left in Georgia and South Carolina are in the Chattahoochee and Sumter National Forests. There, roadless areas overlap 2,500 acres of intact brook trout habitat. Protecting these roadless forests, along with other actions, can help conserve native brook trout.