Read the comments.

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 Fishing has been part of my life from the beginning, passed down from my father and his father before him. From the streams of Fishlake National Forest in Utah to the Kern River in California, I have watched how mountain waters respond to what happens on the slopes above them. These places are vulnerable, and the proposal to rescind the 2001 Roadless Area Conservation Rule would expose them to the sediment runoff, habitat fragmentation, and degraded water quality that new road access brings. This is not where tax dollars are needed, and I oppose this rescission. My husband and I hike and camp in our national forests, not only in California. We watch for eagles, falcons, woodpeckers, and grouse. The grouse matter here in particular. The agency's own record identifies wild turkey and ruffed grouse as species that depend on complex forest structure with mast-producing trees, and notes that sage grouse show strong site fidelity that limits how far they can adapt when habitat changes. Utah alone holds 222 inventoried roadless areas totaling 4,013,529 acres. Rescission would open that landscape to fragmentation that birds like these cannot simply move around. The Northern Spotted Owl and other threatened owl species in our national forests face the same pressure from habitat degradation. I ask the agency to explain, in specific terms, what its analysis projects for upland bird populations and threatened owl species as road access increases in these areas. The agency's own draft environmental impact statement 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 invokes wildfire management as one justification for rescission. Those two things cannot stand together without explanation. I ask that the agency reconcile this proposal with its own ignition data and explain why it is departing from findings that appear in its own record. On the economics, the agency has already found 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 Forest Service's own cost-benefit analysis projects timber revenue to the agency of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. That range does not establish a net benefit. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas, and the costs of degraded source water are real. Building new roads into country where none exist, destroying sensitive ecosystems and fragmenting wildlife habitat, while carrying a backlog of billions of dollars in maintenance for roads already built, is not a responsible use of public funds. The agency must explain on the record how a proposal whose own economic analysis cannot confirm a positive outcome justifies expanding infrastructure the agency cannot currently maintain. The proposal also argues that state-by-state approaches can replace a national rule, but the agency's record documents its own prior dissatisfaction with exactly that logic, noting "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 Ninth Circuit already found that local decision-making can incrementally erode nationally significant roadless values. The agency needs to address how this proposal avoids the deficiencies that court identified the last time a state-by-state approach was attempted. Finally, the proposal suggests the 2001 rule exceeded the agency's statutory authority, but a federal appellate court has already reviewed and rejected that argument. That court stated: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit held that 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 must explain what legal basis it now relies on to reach a contrary conclusion. Public lands belong to the people and should be managed for our use and enjoyment. No private interest outweighs that obligation, and the abundant wildlife within these forests depends on it.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas of Utah are not abstractions to me. I hike and camp all throughout the wilderness here, and I hold a deep conviction that the natural life in these places deserves to remain undisturbed and quiet. I paddle in Fish Lake, Manti, the Uintah national forest including Heber, and many more. I ride trails all throughout the Uinta National Forest, especially near Payson Canyon. The Roadless Area Conservation Rule is the legal backbone that makes these experiences possible, and the proposal to rescind it, Docket FS-2025-0001, would do irreversible harm to places I know and care about. The North Peak roadless area in the Uinta National Forest covers 15,673 acres, and I camp there multiple weeks throughout the year. I have watched that area carry the scars of wildfire, and the connection between road access and fire risk is not speculative. 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 DEIS reinforces this with ignition data: "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." Given that the proposal justifies rescission partly on wildfire and fuels management grounds, I ask that the agency explain why it departs from these prior findings, and that it quantify the expected increase in human-caused ignitions from new road access and weigh that increase honestly against any claimed reduction in wildfire hazard. The Haystack Hill roadless area, 6,255 acres in the Uinta National Forest, is a place I return to many times throughout the year. The canyon is already heavily traveled along the roads that exist. Opening more roads does not serve recreation or quiet; it opens the door to extraction that degrades the landscape. That concern extends across all six of the inventoried roadless areas I am writing about: Levan Peak at 22,092 acres in the Manti-La Sal National Forest, Sanpitch at 29,129 acres in the Manti-La Sal, Oak Creek at 54,053 acres in the Fishlake National Forest, and Big Horseshoe at 17,557 acres in the Manti-La Sal. Hiking Big Baldy in the Sanpitch area was an important part of my experience growing up, and the current rule is what I have relied on to know that area would be maintained. Camping near Oak Creek, the quiet of it, matters to me. The Big Horseshoe trail is absolutely gorgeous and needs to be preserved. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres, and the rescission places all of it at risk from decisions made area by area without the structural protection the rule provides. 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. That omission is not a procedural nicety. Under established administrative law, an agency changing course must identify and genuinely assess the reliance interests its prior policy created. This comment is one such interest. The agency must identify and weigh the reliance interests described in the comments it receives, including mine, before it proceeds further. The regulatory flexibility analysis reaches its no-significant-impact conclusion by spreading losses across every small firm in the sector nationally, rather than examining the outfitters, guides, and tour operators who actually hold permits in the affected areas. The DEIS 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 per year. A certification of no significant impact on small entities cannot survive that contradiction. The agency should withdraw that certification and replace it with an analysis focused on the small entities actually operating in these roadless areas, not a national average that dilutes the real harm. The Manti-La Sal and Uinta watersheds that sustain these places are not isolated from communities downstream. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. Road construction disturbs soil and increases sedimentation in ways that the current rule was designed to prevent, and the rescission creates no substitute protection. The agency has not demonstrated that downstream water quality will be adequately safeguarded, and it should be required to say plainly how it will be. Sincerely, Nathan Jones Spanish Fork, Utah

I strongly oppose the proposal to rescind in part or in full the Roadless Area Conservation Rule. I am a landscape photographer and adventurer who visits public lands any chance I get. I see the impacts of human activity with the roads we already have across lands in Inyo National Forest, Los Podres National Forest, Sierra National Forest, Sequoia National Forest, Fishlake National Forest and many others throughout California, Nevada, Utah and beyond. These places are special. I oppose to changing this because more roads will lead to more fires as fires are way more likely to start from human activity near roads than in the wilderness alone. Existing rules already allow for roads in service of fire prevention. The ground disturbance would allow for more invasive species which are a greater fire risk as described in the draft EIS. I’m opposed to allowing commercial logging deeper into wilderness areas when there is plenty of other land already available. It’s unnecessary. The logging activity will disrupt drinking water sources and scar the landscape for short term gains that cause bigger long term losses. The roadless areas can remain roadless and areas can still be logged in a responsible manner. For these and many more reasons, I am opposed to any rescinding of the Roadless Rule in full or in part. Please adopt Alternative 1 (No Action)

Subject: Public Comment: Oppose the Rescission of the Roadless Area Conservation Rule (DocketFS-2025-0001) Dear Secretary Rollins and U. S. Forest Service Officials, I’m writing as a 50-year resident of Utah and frequent user of the Uinta-Wasatch-Cache National forests. I strongly oppose rescinding or even weakening the 2001 Roadless Area Conservation Rule. Utah has 8000 miles of roads and 2000 miles trails overseen by the BLM. And the Forest Service oversees 10,000 – 20,000 miles of roads and trails in Utah. Utah’s Fishlake National Forest is home to the largest living organism in the WORLD, “Pando”, a clone of quaking aspens covering 106 acres—this is something to cherish, celebrate and protect. Across the United States the U.S. Forest Service oversees 380,000 miles of roads—that’s 8x longer than the entire U.S. Interstate System. We’ve already seen cuts to the agencies who maintain these roads and trails—we don’t need any more. The roadless areas in our state provide wildlife habitat and corridors and they serve as watersheds for our community’s drinking water. Please preserve the integrity of Utah’s public lands keep the protections of the 2001 Roadless Area Conservation Rule intact, Sincerely, Julie Simonds 6315 Snowview Dr Park City, UT 84098

I am a Utah resident and a frequent user of our National Forests and other public lands for hunting, fishing, camping, hiking, and river recreation. I am writing to oppose the blanket rescission of the Roadless Area Conservation Rule. I support responsible active management of our National Forests. I believe there are legitimate reasons for thinning forests, reducing hazardous fuels, improving wildlife habitat, and constructing roads where there is a compelling, site-specific need. However, I do not believe those objectives require eliminating roadless protections nationwide. As a hunter, I particularly value the remote and undeveloped areas of our National Forests. Roadless areas provide opportunities for hunting and other recreation that cannot simply be replaced by creating additional motorized access. Once a road is constructed into an otherwise roadless area, the character of that area can change permanently through increased vehicle use, noise, development, and recreational pressure. Utah already has enough trails. I live in the FishLake National Forest and I wish there were more roadless areas. It's pretty rare to be able to hike 3 miles without crossing another road. I am also concerned that wildfire mitigation is being used as a justification for a much broader change than is necessary. I support targeted fuels reduction and strategically located access where it can demonstrably protect communities and improve fire response. Those needs should be evaluated on a site-specific basis by local managers rather than used as a reason to eliminate protections across millions of acres where such measures may not be necessary. If logging or prescribed burns are necessary to help reduce fuels in a specific area, block off those roads to once finished to keep them roadless. I encourage the Forest Service to retain the Roadless Area Conservation Rule while continuing to pursue responsible forest management and wildfire mitigation where needed. Local managers should have flexibility to address legitimate management needs, but that flexibility should exist within a national framework that preserves some of our remaining roadless public lands. As a public-land user, I believe we can manage our forests aggressively where management is needed while also preserving some places where people can still experience truly remote public lands.

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I have personally spent time in Utah’s extraordinary public lands, including the Grand Staircase-Escalante region, and the experience profoundly affected me. There are places where the absence of development is itself part of what we are protecting. The scale, silence, ecological integrity, and sense of uninterrupted landscape cannot simply be recreated once roads and development fragment it. I am also deeply concerned about the future of Utah’s Fishlake National Forest, including Pando, the remarkable aspen clone that represents one of the world’s largest known living organisms. Places like this are not ordinary parcels of land. They are living ecological systems whose value extends far beyond any immediate commercial use. The Roadless Rule provides a consistent national safeguard for inventoried roadless areas. Replacing that protection with decisions made project by project or forest by forest creates the possibility of fragmentation that may be impossible to reverse. Roads do not affect only the ground beneath them. They can alter habitat, watersheds, wildlife movement, fire and invasive-species dynamics, and the character of landscapes that have remained largely undeveloped. These lands also belong to generations who have not yet had the opportunity to experience them. I was fortunate enough to stand in the landscapes of southern Utah and experience something that I still carry with me. Future generations deserve that same possibility. I respectfully request that the Forest Service retain the 2001 Roadless Area Conservation Rule and its nationwide protections for inventoried roadless areas, including roadless lands within Utah’s National Forests. Some places have value precisely because we have chosen not to build through them. Once that continuity is lost, we cannot assume we will ever get it back. Warmly, Katrina Elkins San Francisco CA