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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Mount Olympus near Salt Lake City is a unique and special place for the million-plus people living in the region. I was married near Boulder Mountain, in the Dixie National Forest, and it is a gorgeous and special place that needs to remain protected. So many of the unique wild areas of Utah and surrounding states are protected by the roadless rule. The rescission of the 2001 Roadless Area Conservation Rule would put all of these places, and the other roadless areas in Utah I am naming here, at serious risk. I oppose Docket FS-2025-0001 for the reasons below. These regions bring huge amounts of tourism income to Utah and contribute to making it the amazing and unique place that it is. Utah 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 people of Salt Lake City depend on the landscape that includes the 9,982 acres around Mount Olympus and the 6,157 acres at Twin Peaks, both in the Wasatch-Cache National Forest, for clean water and for the outdoor character that defines the place. The 110,690 acres of Boulder Mountain, Boulder Top, and Deer Lake, and the 19,581 acres of Table Cliffs and Henderson Canyon, both in the Dixie National Forest, are part of the same connected system of protection. Rescinding the rule would expose all of this to road construction and the impacts that follow. The agency's stated justification includes wildfire and fuels management, but its own record contradicts that rationale. The agency has found: "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." Given that finding, the proposal's premise that opening roadless areas to road construction serves fire management goals is not coherent. The agency must explain why this proposal departs from its own prior findings, and it must 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. On economics, the agency has acknowledged: "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 record projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, while the existing road system already carries a $6.9 billion maintenance backlog. The agency has not shown that this action produces a net benefit, and it owes the public a direct accounting of how expanding a road system under those fiscal conditions is justified by the numbers in its own cost-benefit analysis. The proposal argues that state-specific approaches can substitute for a national rule, but this path has been tried before. The agency's own record reflects "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." What the record does not explain is how a state-by-state replacement avoids the deficiencies that led a federal appellate court to reject that approach the last time the agency tried it, and the agency's prior own finding that local decision-making can incrementally erode nationally significant roadless values. The agency should answer that question squarely. Finally, the proposal questions the statutory authority behind the 2001 rule. The courts that reviewed this directly held otherwise. The Tenth Circuit stated: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the 2001 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 has not explained in this proposal what legal basis supports a contrary position, and it should.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 For 45 years I have owned a home on the Forest Service boundary of the north slope of Boulder Mountain. I know this landscape through decades of hiking, bird watching, and looking for those sneaky elk across the soaring cliffs of Navajo sandstone that mark the terrain. Boulder Mountain is the source of the water for the well that serves my home. I am a voter in Wayne County. I am back at that home constantly, and I will be there again tomorrow, October 7, 2026. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask the agency to answer each of the points below. Boulder Mountain, Boulder Top, and Deer Lake together make up 110,690 acres in the Dixie National Forest. Over the last half century I have watched more people arrive, less wildlife remain, and the risk of vehicle-caused wildfire grow. More roads mean more noise, more trespass, and more fire risk. That is not a feeling. The agency's own record states it directly: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission in part on wildfire and fuels management grounds, and that justification runs straight into the agency's own data. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The birds I watch and the elk I look for depend on unroaded habitat. The agency's own DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Elk avoid areas near roads and select habitat away from them; the agency's own cited research found elk survival rates rose during a road closure and fell again when the gates were removed. These are not abstract concerns. They describe what I have already watched happen across Boulder Mountain in the time I have known it. The agency must explain on the record how it weighs these documented effects on wildlife against the claimed benefits of rescission. The proposal also rests on the premise that the current rule blocks necessary management. The agency's own language undercuts that premise: the rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Public health and safety construction is already permitted. Community wildfire protection and existing mineral leases are already addressed. The agency has not identified which specific burdens are not already covered by these exceptions. I ask that it do so, with specificity, and quantify those burdens on the record. The regulatory flexibility analysis accompanying this proposal certifies no significant impact on small entities. That certification cannot stand. "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 analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas. 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 economic stakes for the specific businesses and communities tied to these places are not captured by a national average. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. Finally, this comment is itself a reliance interest. I have owned my home, drawn my water from a well fed by Boulder Mountain, and made decisions about how and where I live based on the protections the 2001 rule put in place. The agency 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. An agency reversing course must assess what its prior policy created. The agency should identify and weigh the reliance interests described in the comments it receives, including this one. Scott Berry Teasdale, Utah

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in Southwestern Colorado, and have spent years exploring much of the west. I work, recreate and live within areas that are currently protected by this measure, and cannot imagine the impact this would have on places I hold close. I worked for years in the Frank Chruch River of No Return Wilderness area, a place that truly cannot be described in words. The most amazing part of that place is that is it has no roads. I have also worked in the Six Rivers National Forest in Northern California, who’s endangered chinook salmon population would be at risk. Outside of work, I have spent countless hours in the Fishlake National Forest, Ashley National Forest, and Dixie National Forest in Utah. All of these places deserve to be protected in their current state. Rescinding the “2001 Roadless Rule” puts countless resources, ecosystems and recreation areas at risk. These places I’ve listed (along with all others affected by this potential measure) protect drinking water resources, preserve old growth habitats, store carbon and support wildlife that we all enjoy. These areas are crucial to local people, for water, food and shelter. Please do nott rescind this preservation measure.

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.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Public lands are one of the few things that make me feel good about being an American these days. My family and I hike and camp all around the Dixie National Forest and the surrounding Great Basin area, and I photograph the glory of nature wherever I find it, for fear that some of the things I photograph may no longer exist in the future. That fear is what brings me to this docket. I am opposed to rescinding the 2001 Roadless Area Conservation Rule. The agency frames this proposal partly as a wildfire management measure, but its own record undermines that framing. The agency 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." The DEIS Table 21 reportedly confirms higher fire density on roaded land than inside the affected roadless areas. I ask that the agency explain how the proposal departs from these findings and reconcile the rescission with the ignition data its own environmental review produced. The economic case for rescission is equally weak. The agency's own 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." The agency's cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million. The road system the agency proposes to expand already carries a $6.9 billion maintenance backlog. The agency's own numbers cannot establish a net benefit. I ask directly: how does an action with that range of outcomes justify enlarging a road network the agency already cannot afford to maintain? The agency argues that state-by-state approaches can replace one national rule, but the record shows the agency previously tried exactly that. A federal circuit court reversed the approach, finding the agency lacked the legal ground to stand on. The prior effort also rested on dissatisfaction with what the agency described as an inflexible nationwide rulemaking approach, language that appears in the current record as well. The agency needs to address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the same deficiencies the courts identified before. That explanation is owed to the public on the record. On the statutory authority question, the Tenth Circuit resolved this once already. The court found, in reversing a district court injunction against the 2001 rule, that "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 court concluded the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and that it did not create de facto wilderness. The current proposal implies a contrary position without squarely addressing that holding. The agency must explain the legal basis for departing from a court's direct ruling on the scope of its own statutory authority. Public lands should not be up for grabs by greedy investors and developers. The Dixie National Forest and the Great Basin landscapes around it belong to the public, and the record before this agency does not support the conclusion that rescinding a rule protecting them serves any demonstrated public interest. I urge the agency to withdraw this proposal. Sincerely, Jean W. Frenette III Ivins, Utah

In considering the potential rescission of the Roadless Rule, which was enacted in January 2001 by the Clinton administration, one thing should be very clear: the federal government cannot afford to maintain the 380,000+ miles of road that currently exist within the National Forest system. This is eminently obvious to anyone who has hopped in a 4x4 vehicle to brave something that the local USFS map says is a road but turns out to be a pitted, overgrown path that was probably last traveled by a vehicle thirty years ago. Indeed, it is obvious to the USFS itself, whose own fact sheet following the introduction of the Roadless Rule cited a growing $8.4 billion deficit in road maintenance and claimed it only receives up to 20% of the annual funding that would be necessary to maintain the entire system: https://www.fs.usda.gov/eng/road_mgt/qanda.shtml I am struggling to understand under what circumstances it makes sense to put even more taxpayer money toward constructing new roads when we cannot maintain the roads we have. Another argument in favor of rescinding the Roadless Rule is that new road access will improve wildfire preparedness by making it easier for USFS to conduct forest management in remote areas. Again, USFS simply cannot afford the increased cost of road construction, maintenance, and forest management that would come with this endeavor. Moreover, USFS acknowledges that the vast majority of human-caused fires begin within half a mile of a road. Increasing access to these remote parts of the National Forest system will only increase chances of humans causing the deadly fires that the Forest Service seeks to prevent. I'd also like to point out that the forest ecologies within many of the inventoried roadless areas evolved to require periodic fire to clear undergrowth, cycle nutrients, and release conifer seeds from their cones. Forests become less healthy and more dangerous when their natural fire cycles are suppressed. This is not to speak of the value of wilderness itself, which is beyond measure. Our public lands are our greatest treasure, and the wild areas within these lands are unlike nowhere else on Earth. The very idea of wilderness is integral to the American ethos (what is the "wild West" if not wild?). In 1960, Wallace Stegner closed his famous Wilderness Letter by remarking that just knowing the wilderness is there is enough: "We simply need that wild country available to us, even if we never do more than drive to its edge and look in. For it can be a means of reassuring ourselves of our sanity as creatures, a part of the geography of hope." I am proud to live, work, and recreate in Utah—the vast majority of whose land is federally owned and operated—which makes it easy for me to do exactly as Stegner suggests and just drive to the edge of the wilderness and peer in. Whether I'm in the lake-studded coniferous forests of the Uinta Mountains (Uinta-Wasach-Cache and Ashley National Forests) or among the sharp red hoodoos that mark the boundary between the Great Basin and the Colorado River (Dixie National Forest), the very act of contemplating the depth and breadth of the landscape around me is a profound experience that connects me to the past, present, and future of the land. It is an experience I hope every lawmaker in the room has the chance to partake in someday. Thank you for your time & consideration in reading my comment.

I am opposed to the revocation of the 2001 Roadless Rule in National Forests. I am a kayaker, hiker, biker, and camper. Over the past 35 years I have visited at least 25 National Forests across 14 states, from Georgia to West Virginia, over to South Dakota and down to Utah, including almost all the National Forests in Colorado, Chequamegon-Nicolet (WI), Cherokee (NC, TN), George Washington and Jefferson (VA), Monongahela (WV), Black Hills (SD), and Dixie and Manti-La Sal (UT), among many others. All of these forests have roadless areas. As an outdoor enthusiast, in addition to recreating, I go to National Forests to enjoy their spacious serenity and beauty and to be a part of nature for a while. Even as I sit here, I revel in the images of the Sunrise and Pine Lake Campgrounds and Candy Cliffs/Yant Flats area in Dixie National Forest from my most recent trip. My time in these wild places not only nourishes my well-being but deepens my reverence for the non-human beings that live there. I think the forests are accessible enough already to humans and believe deeply in ensuring that wildlife have protected natural environments in which to live. Revocation of the Roadless Rule could have numerous adverse effects. on ecosystems, including wildlife, and on humans: (1) New roads in roadless areas would segment intact ecosystems that species such as elk, lynx, and grizzly bears need. Intact forests filter water naturally and better serve the 60 million people who depend on water from national forests. Trout and salmon, depend on undammed streams whose banks are unlogged. (2) Given the overall anti-environment, pro-development policy orientation of the Trump administration, it is justifiable to surmise that roads in the now roadless areas are intended for extraction of forest resources and for other development. Extraction activities (mining, logging, and drilling) damage and destroy ecosystems much beyond that of the roads themselves, and therefore wildlife habitat and negatively impact biodiversity. In addition, these activities involve disruptive amounts of noise that impact wildlife and humans. Furthermore, the Trump administration has not provided adequate justification for the revocation. The administration’s rationale that roads in roadless areas are needed for fire management is rebutted by the following findings from Forest Service reports(*): (1) 80% of wildfires in National Forests are started by humans within a half mile of forest roads. Thus, roads in now roadless areas create enhanced opportunities for human-started fires deep in the forest. (2) Management for fire prevention in roadless areas already exceeds that in roaded areas; also, exceptions are built into the 2001 Roadless Rule for activities for fire prevention and management. There is a backlog of maintenance needs on forest roads amounting to millions of dollars. Given that the Trump administration has stripped the Forest Service of funds, allowing for new road building does not make sense. Presumably, the administration is creating another opportunity for private businesses to profit from public lands and taxpayers. The 2001 Roadless Rule garnered the highest level of support from public comments in the history of the Forest Service and should not be revoked. *Reported in “The Real Reason the Forest Service is Killing the Roadless Rule” by Natalie Krebs. Outdoor Life. August 26, 2026. https://www.outdoorlife.com/conservation/roadless-rule-deregulation/.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My family owns a cabin that backs up to the Dixie National Forest in Utah. That is not an abstraction. The Lava Beds roadless area, all 14,944 acres of it, is part of the landscape I grew up on. I hiked on it, around it, beneath it, and looked down from it as a child. I lost my brother to a hiking accident in Snow Canyon State Park. These are not distant federal lands to me. They are the ground my family stands on. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The Dixie National Forest holds roadless areas including Timbered Cinder Cone, Hancock, Mineral Canyon, Bunker Creek, Bear Valley Peak, and Lava Beds, among others. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres. I have watched what happens when land management is hurried and careless. I have seen logging harm streams, decrease fish, and change the landscape in ways that do not reverse. I have seen poor management during and after roadwork displace wildlife and wreck havoc on the immediate ecosystem. Those observations are not ideology. They are what I have seen with my own eyes in country I know personally. The agency's own record makes a finding about fire that directly contradicts the reasoning behind this proposal. 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." If the agency is rescinding protection of roadless areas partly on wildfire management grounds, it must explain why it is departing from that finding. I ask that the agency reconcile this proposal with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain that departure in plain terms. The state-by-state approach this proposal leans on has been tried before. The agency's own record acknowledges 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." That rejection led to litigation the agency lost. The Ninth Circuit identified deficiencies in the local-rule approach. The agency has not explained how this proposal avoids repeating those same deficiencies, and it has not addressed its own prior finding that local decision-making can incrementally erode nationally significant roadless values. The agency should answer that question directly before this proposal advances. The proposal also asks the public to comment on something the agency simultaneously declares out of scope. The record reflects: "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." That is not a fair comment process. The foreseeable plan-amendment scenario, including expanded timber harvest area across places like the Dixie National Forest roadless units I named, must be analyzed as part of this action, not deferred to future proceedings the public cannot yet see or contest. On carbon, the agency identified a significant number and then declined to follow it through. "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." The DEIS reaches no conclusion about what roading and harvest would do to that figure. I ask that the agency quantify the change in carbon storage and sequestration under each alternative before it finalizes anything. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The Colorado River allocation debate is already putting water in this region at serious risk. Opening these watersheds to roads and timber operations adds pressure that is not accounted for in this proposal. The agency is responsible for the conservation and protection of the land and resources that made this country what it is. My children have the right to live on this land as it is. We have plenty of roads and developed areas already. Without these protections, that will be the only thing left. The agency should answer each of the points raised here in the record before any final action is taken. Sincerely, Rebecca Shillander Utah

Dear USDA Forest Service Planning Team, I am commenting to express that I strongly oppose the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule, and I urge the U.S. Forest Service to select Alternative 1 (the 'No Action' Alternative) to keep all protections in place. I have spent a great deal of time in various areas currently protected under the National Roadless Rule, including but not limited to Green Mountain National Forest, White Mountain National Forest, Allegheny National Forest, Monongahela National Forest, Dixie National Forest, Uinta National Forest, as well as Pike, San Isabel, Gunnison and White River National Forests protected under the Colorado Roadless Rule. In these places I have met and lived with people who are dependent on the preservation of this rule- whether they rely on local watersheds for drinking water (roadless areas protect critical municipal water sources and drinking water for more than 60 million Americans across dozens of states), or whether they recreate like myself (hike, fish, hunt, camp, or mountain bike), or rely on the preservation of lands for that recreation to sustain their employment and local economy in specific inventoried roadless areas (IRAs). All of this of course, and still yet to mention the catastrophic impact rolling back this rule would have on habitat and wildlife, old growth and climate. Because the existing rule already permits necessary management and emergency fire response, opening 58.5 million acres to new commercial logging, mining, and road construction is unnecessary and harmful. Please preserve the 2001 Roadless Rule in its entirety. Sincerely, Lisa (Bolduc) Bobowicz East Aurora, New York

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Taking all eight of our grandchildren into Dixie National Forest, pointing out the firs, the aspens, the scat on the trail, the wide vistas from the high ridges, and watching them discover their connection to the Earth: that is what roadless protection made possible. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this letter be entered into Docket FS-2025-0001. The strongest argument against rescission is the agency's own numbers. The Cost Benefit Analysis cannot establish a net benefit from this action, projecting a net present value ranging from negative to positive across its own scenarios, while booking recreation losses at a minimum of $6.1 million a year against timber revenues that may never materialize. The record on the Tongass makes the pattern clear: "By contrast, the Defendants estimate the timber industry supplies only 337 jobs, just one percent of regional employment, and $18.8 million, one percent of earnings, in the region today. Defendants project that, the rule will not result in any new timber industry jobs on the Tongass over the next 100 yrs and regional economic impacts from the timber industry will remain the same with the Exemption as without. FEIS at 3-55." I ask that the agency reconcile this proposal with that economic record, that it explain how an action producing no projected employment gain justifies expanding a road system already carrying a $6.9 billion maintenance backlog, and that it answer this question plainly on the record. Bunker Creek, at 7,474 acres within Dixie National Forest, and the Lava Beds area, at 14,944 acres in the same forest, are the kind of undisturbed places the 2001 rule was written to protect. Our grandchildren adored the ancient lava beds and what the geology of that landscape could teach them. A road through the Lava Beds would ruin the natural flow of rocks and color. Permanent roads into Bunker Creek and the extractive industry access that would follow would destroy the balance in what I can only call a very special environment. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres, and across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The agency has not explained how opening these lands serves the public that depends on them. The agency's own record is candid about the economics: "Development activities in inventoried roadless areas often cost more to plan and implement than on other National Forest System lands. Some planned timber sales in inventoried roadless areas are likely to cost more to prepare and sell than they realize in revenues received. Because of the level of public controversy and analytical complexity, projects in roadless areas often require development of costly environmental impact statements for most resource development activities, including timber harvesting, in inventoried roadless areas. In some cases, road construction costs are higher due to rugged terrain or sensitive ecological factors. Many development projects in inventoried roadless areas are appealed or litigated." I ask that the agency identify which specific permitting burdens are not already addressed by the rule's existing exceptions for public health and safety, existing mineral leases, and community wildfire protection, and that it quantify those remaining burdens with specificity. We looked for beaver ponds and small wildlife in the beaver lake area and found the undisturbed nature of our surroundings to be the whole point. Our public lands belong to all Americans and all generations, not to a single administration's revenue calculus. The small-business certification attached to this proposal contradicts what the analysis beside it concedes: the DEIS names outfitters, guides, and tour operators as affected parties, and the Cost Benefit Analysis itself books lost recreation benefit at a minimum of $6.1 million a year. Spreading that loss across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas is not analysis. The agency must withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. These roadless areas, identified in 2001, should be kept intact for generations to come. 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. Families like mine planned around this protection. Teaching our grandchildren about firs, aspens, beaver ponds, and ancient lava geology was possible because the rule held. That reliance is real, it is documented in comments like this one, and the agency is required to identify and weigh it before changing course. Sincerely, Judy Kirshner, Los Angeles,CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Challenging myself with survival in the wild is an instrumental part of my fulfilled life. I walk the wilderness to connect with my innermost human spirit, and God is with me. I have personally experienced the freedom of mind and faith that our American wilderness areas afford to any hiker, hunter, angler, sportsman, or salvation-seeker, and I return to these untrammeled places again and again: the Kilkenny and Presidential-Dry River Extension units of the White Mountain National Forest in New Hampshire, the 1,483,000-acre Bob Marshall Wilderness Complex in Montana, the Bridger-Teton National Forest in Wyoming, the Hermosa and West Needle units of the San Juan National Forest in Colorado, Casto Bluff in the Dixie National Forest in Utah, and the Salmon-Challis National Forest in Idaho. These are not abstractions. They are where I seek what footpaths have always made possible. The creation of a road where none has been needed before, where footpaths have always sufficed, would greatly diminish the legacy I wish to leave to my children and generations to come. I do not want to be among the last Americans to experience wilderness in all these unique areas of our great country. The White Mountain National Forest exists in part because of what happened when New England's mountains were clearcut, a history that moved Congress to pass the Weeks Act of 1911. Its 16 inventoried roadless areas total 240,669 acres and form the headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. Roads change what a watershed delivers downstream. The agency should explain to the communities drawing from these headwaters what standard it applied to their interest in this rescission. The Bridger-Teton contributes the western extension of the largest intact temperate ecosystem in the world with 1,417,499 acres of inventoried roadless land. The DEIS quotes the federal grizzly recovery plan: the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. I ask the agency to explain, for the record, how it weighs that finding against the proposed rescission. The agency's own fire data does not support its direction. "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. The agency should quantify the expected increase in human-caused ignitions from new road access and weigh it honestly against the claimed reduction in wildfire hazard before proceeding. The regulatory flexibility analysis reaches its no-impact conclusion by spreading expenditure losses across every small firm in the sector nationally rather than assessing the outfitters and guides actually holding permits in the affected areas. Yet "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 agency should withdraw that certification and assess the impact on the small entities actually operating in these areas, not the national average. Finally, the agency both restricts and expands its own scope in the same document. "The proposed rule concedes that subsequent revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." That revision scenario, including any expansion of timber harvest area, must be analyzed as part of this action, not deferred. The agency should identify and weigh ALL reliance interests described in the comments it receives before it acts. I have worked alongside NFS crews to clear trails in the Bob Marshall Wilderness for better access by hikers and horseback riders, never for vehicles. And I have felt pride when making a new friend because I helped his or her passage on horseback through the Bob. I strongly advocate for a formal, affirmative policy for wilderness areas of "Keep it Wild". I strongly oppose removing the Roadless Rule and ask for the Forest Service to adopt a "no action alternative" to keep the Rule intact, as it was written in 2001. I urge you to conserve our nation's roadless forests and keep the Roadless Area Conservation Rule in place. Sincerely, David A. Carre Wayne, Pennsylvania

Re: Special Areas; Roadless Area Conservation – Proposed Rescission and Draft EIS My name is Chris Cochella a long time user of our public lands to raft, kayak, bicycle, hike and simply enjoy. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service to choose the No Action alternative in the final EIS. I live in Utah. About 4 million acres here, nearly half of our national forest land, are inventoried roadless areas. They include the backcountry of Big and Little Cottonwood, Millcreek and American Fork canyons, the Uintas, and the Dixie National Forest. I have traveled many miles of existing Forest Service roads by car, bike and on foot. We have plenty of roads. What we can't make more of is intact backcountry. 1. The agency's own analysis does not support the wildfire argument. The Draft EIS acknowledges three things: Wildfire ignitions increase as road density increases. Roadless areas currently have fewer fire starts than other national forest lands. Any gain in fuel-treatment capacity from rescission would be "modest." Most wildfires are human-caused, and most start near roads. The current rule already allows thinning, and even road building, to reduce wildfire risk or protect public safety. About 2 million roadless acres have already been treated under it. The fires that destroy homes burn in the wildland-urban interface, which already has roads. New roads in remote backcountry protect few structures and add new sources of ignition. 2. Taxpayers cannot afford more roads. The Forest Service already has a deferred maintenance backlog of roughly $7 billion on the roads it has now. The DEIS admits that timber revenue would not cover the cost of building and maintaining the new roads that rescission would allow. The projected $5–11 million a year in new timber revenue nationwide is small compared with that cost. Unmaintained roads also erode, sending sediment into streams and fisheries. 3. Roadless areas protect drinking water. These areas protect hundreds of municipal watersheds. Along the Wasatch Front, the Cottonwood canyons are a drinking water source for the Salt Lake Valley. Road building and logging in source watersheds degrade water quality and raise filtration costs for the people downstream. 4. Recreation supports far more of the economy than logging. Recreation is the single largest part of the national forests' economic contribution. It produces more jobs and more GDP than timber. Utah's outdoor recreation industry is worth billions a year. Moab is a good example. It used to be a dusty mining town and is now a thriving recreation economy. Hunting, fishing, hiking, biking and skiing do not need new roads, and they lose value when backcountry is roaded and logged. 5. Rescission is not a neutral return to "local control." Most of Utah's roadless acres sit in areas where current forest plans would allow road construction. For tens of millions of acres nationwide, the Roadless Rule is the only thing preventing new roads. Removing it is not a simple handoff to local managers. It removes the only protection these lands have. 6. The process is inadequate. The 2001 rule was developed through more than 600 public meetings and a 120-day comment period, and it drew about 1.6 million comments. This rescission allows a short comment period and holds no public hearings. A rule built with that much public input should not be undone with this little. The Roadless Rule has worked for 25 years. It balances wildfire management, clean water, wildlife and recreation, and its existing exceptions already allow the work the agency says it needs to do. Please keep it in place.

Subject: Oppose Rescission of the 2001 Roadless Rule – Docket FS-2025-0001 Attention: U.S. Forest Service, Department of Agriculture I am writing in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule Docket FS-2025-0001. I explicitly oppose any changes that would open these intact lands to new road construction. As a resident of Washington, Utah, I deeply value the pristine, undeveloped nature of our nearby public lands. I regularly hike on Cedar Mountain, explore the Ashdown Gorge Wilderness area, and recreate on trails like Yant Flat within the Dixie National Forest. The inventoried roadless areas in these specific landscapes are vital for protecting the remote character, scenic beauty, and fragile ecosystems of Southern Utah’s high-altitude forests and red rock backcountry. Building roads into these intact areas permanently fragments critical wildlife habitats, degrades soil stability on steep canyon terrain, and threatens the purity of municipal watersheds that our growing desert communities rely on. Furthermore, introducing vehicle corridors into remote backcountry areas significantly increases the risk of human-caused wildfire ignitions in an area already prone to severe drought and fire risk. Local forest planning cannot replace the uniform, durable protection that the 2001 Roadless Rule provides. I urge the Forest Service to withdraw this proposal and keep the roadless areas of the Dixie National Forest entirely free of road development. I have attached photographs of the Cedar Mountain, Ashdown Gorge, and Yant Flat areas to illustrate the scenic, ecological, and recreational values that could be harmed by new road construction. Sincerely, Southern Utah Hiker

I support not only protecting the roadless rule, but extending it and increasing the total coverage of roadless area in the United States. Removing or reducing the roadless rule puts threat to many of the priceless wilderness areas of the United states. This will threaten the natural resources, biodiversity, beauty and recreational value of natural areas in the US from Tongass national Forest in Alaska to Dixie National Forest in Utah. Reduction of the roadless rule would be an irresponsible and irreparable mistake

I am an avid outdoor recreationist who regularly visits roadless areas on America's national forests and I support the No Action alternative in the current DEIS. I am deeply concerned with the idea of rescinding the Roadless Rule, which is extremely important to the outdoor recreation community and the outdoor recreation economy. The rescission would remove important protections for approximately 45 million acres of backcountry national forests, including more than 25,000 miles of trails, 10,000 climbing routes, nearly 1,000 miles of whitewater, and more than 10,000 miles of mountain biking. Furthermore, rescinding the Roadless Rule would significantly reduce areas of public, nonmotorized recreation, and increase the likelihood of accidents, injuries and fatalities between motorized and nonmotorized users of US national forests. As a mostly non-motorized trail user, I have encountered many close calls with reckless drivers in USFS areas that both do and do not benefit from the protection of the Roadless Rule. I have benefited greatly from the Roadless Rule protections, specifically in the Manti-La Sal National Forest, in the Gold Basin and around Mt. Tukuhnikivatz outside of Moab, UT; in the Dixie National Forest near Escalante, UT; and during backpacking trips throughout the Wasatch-Cache and Ashley National Forests in northeast Utah. These areas would be irrevocably harmed by the rescission of the Roadless Rule -- in their natural beauty, serenity, safety, and quality of wildlife habitat. Hunters, fishers, skiers, hikers, backpackers, bicyclists, and other non-motorized users would be directly and negatively affected, permanently. USFS land outside of the roadless inventory already vastly exceeds the land under the protection of the Roadless Rule. Outdoorsmen and outdoorswomen already have fewer areas to enjoy nature than people that prefer motorized recreation. I strongly support maintaining the Roadless Rule as is. Outdoor recreation is a crucial part of our country's economy, and rescinding the Roadless Rule is unpopular, unnecessary, and potentially dangerous.

I recently visited southern Utah and drove through the extraordinary landscape around Grand Staircase-Escalante and Dixie National Forest. What struck me most was the vast expanse of unpeopled, undeveloped land stretching as far as I could see. I had never seen anything like it. The views were breathtaking in large part because there were so few visible signs of human development. These landscapes are priceless and irreplaceable. Their extraordinary rock formations and sweeping vistas cannot simply be reconstructed once they have been physically altered by roads or development. We can't fix it if we break it. I was also struck by how many international visitors were there. During our trip, I heard people speaking French and Italian. People are traveling from other countries to experience this landscape because it is so extraordinary. Preserving its undeveloped character protects one of the very qualities that draws people to southern Utah in the first place. For the roadless areas in Dixie National Forest, I am particularly concerned about permanent visual and physical alteration from road construction. These areas should remain roadless. Some places are treasures precisely because we have left them alone, and this is one of those places. I urge the Forest Service to retain Roadless Rule protections rather than rescind them.

Please do NOT rescind the Roadless Rule! The 2001 Roadless rule was a bipartisan rule that went through a lengthy public comment period. Rescinding now is ill conceived and not in the American people interest. More roads will create more forest fires and not prevent them. Forest fires are mostly started by humans with dragging chains, tossed cigarettes, campfire not extinguished. As a person who backpacks, hunts and hikes, knowing that our forests are protected for future generations across all states is what makes the 2001 Roadless rule so valuable and is irreplaceable. I urge you to visit Dixie National Forest in southern Utah and see for yourself the web of roads and the destruction of the forest near Duck Creek Village. We need to manage the roads we already have and increase the funding to take care of them. We also need our forest to be healthy, wildlife habit not fractured, and our streams free of sediment not caused by nature. Please adopt the No Action alternative for the Final Rule.

I am submitting this comment in opposition to the USDA's proposed rescission of the Roadless Area Conservation Rule (Docket No. FS-2025-0001). I am an avid proponent of the USA's wildlands, including Utah's Dixie National Forest and Ohio's Wayne National Forest. Recreating in these spaces, unimpacted by roads, is a privilege we must preserve for future generations. Wildlife will be negatively impacted by vehicle traffic in our few remaining tracts of wild land. This proposal does not reduce wildfire risk or have meaningful benefits for the American people. I urge the Forest Service to select Alternative 1 and keep the Roadless Area Conservation Rule fully intact.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Undeveloped land is where I go to feel in touch with nature and get away from the stress of daily life. I hike and camp in places like Mineral Canyon and Bear Valley Peak, both inventoried roadless areas in the Dixie NF in Utah. Mineral Canyon's red rocks draw me in part because it is much less congested than Zion and Bryce. Bear Valley Peak offers a range of plants that is a pleasure to see. These places matter to me, and the proposal to rescind the 2001 Roadless Area Conservation Rule would put them at risk. I oppose that rescission. The wildfire rationale the agency offers does not survive contact with its own data. The agency's draft environmental impact statement states: "While roads allow more agile positioning of firefighting assets, they are also the site of high rates of human-caused ignition (Narayanaraj and Wimberly 2012), which account for 84% of US wildfires (Balch et al 2017)." Opening roadless areas like the ones I visit to new road construction would bring exactly that ignition risk into places that currently carry lower fire density than roaded land, as the agency's own DEIS Table 21 shows. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and reconcile the rescission with those ignition figures in its own record. The agency also claims the current rule creates administrative and permitting burdens, but the rule as written already accommodates the activities the agency says it cannot do. The DEIS states: "The rule recognizes the need for tree cutting to reduce the risk of wildfire to at-risk communities. It allows tree cutting in non-upper tier within 0.5 miles from the boundary of an at-risk community, or up to 1.5 miles if certain conditions exist and the area is within a Community Wildfire Protection Plan (CWPP). A temporary road may be constructed to facilitate hazardous fuel reduction within 0.5 miles of the boundary of an at-risk community." If the rule already permits these actions, the agency must identify, specifically and quantitatively, which burdens remain unaddressed by the existing exceptions for public health and safety, existing mineral leases, and community wildfire protection. That accounting belongs in the record before any rescission proceeds. I also hike where bears live, and that connection sharpens my concern about what new roads do to wildlife. The DEIS cites the federal grizzly bear recovery plan for the finding that increased contact and conflict in grizzly habitat from open roads can ultimately end in grizzly mortality, and that shooting, habituation, and food reward all increase with use of even secondary unpaved roads. The places I walk in Utah are part of a larger landscape. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres, and across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The cumulative exposure created by rescission, for wildlife and for water, deserves a serious response from the agency in this docket. On economic impact, the agency's own record undermines the regulatory flexibility certification. "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." Spreading a $9 million annual expenditure loss across every small firm in the sector nationally, rather than examining the outfitters and guides actually permitted in the affected areas, does not constitute a meaningful analysis. The agency should withdraw that certification and assess the firms actually operating in these roadless areas. Finally, the agency invited reliance interests and then ignored them. "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 Mineral Canyon and Bear Valley Peak, and my expectation that they remain undeveloped, is exactly the kind of reliance interest the agency asked about. The agency must identify and weigh the interests described in the comments it receives, including this one, before it can lawfully change course. Sincerely, Sanford Krasner Altadena, CA

Hi, my name is Steven Rozmanith and I am a young man living in Boulder, Utah. The Dixie National Forest, protected under the roadless rule, forms important headwaters for the town and myself, with dozens of creeks full of fish and life coming down the aquarius plateau. This part of the forest gets significantly more rainfall than the surrounding desert, so this water is essential for all life nearby. It is also protected by the roadless rule. Utahns have been unfortunately distanced from the process of managing our public resources, with tourism and hunting money buying decisions about our resources instead of the people who live there, in agricultural communities like Boulder. Repealing the roadless rule gives these decision makers another lever to pull to extract resources from the land. This only starts with building roads that cut through wildlife corridors and otherwise clean watersheds while reducing water retention in the soil. It extends to opening up new land to logging and other practices that will lower water retention in the soil and lower the quality of life for people on the aquarius plateau. Please keep the roadless rule to protect the people who have been disenfranchised by our lack of wealth.