Read the comments.

I submitted comments to the proposed rule in Sept 2025. Attached below. Consider these integral to my current comments. I strongly oppose recission of the 2001 Roadless Rule. I served on the roadless rule Content Analysis Team (CAET) in 2000, we read and synthesized all comments. Sentiment strongly favored protecting roadless areas and benefits they provide: clean water, biological diversity, wildlife habitat, forest health, and recreation. Climate change and population growth have increased support for roadless areas. I worked on the WMPZ Forest Plan Revision Team for forests in Western Montana; Flathead, Lolo, and Bitterroot. Despite efforts and substantial expense by American taxpayers, these were shelved due to a national lawsuit. Courts ruled the 2005 planning rule was inconsistent with the National Forest Management Act. The Flathead National Forest completed its forest plan revision in 2018 under the 2012 planning rule. My September 2025 comments must be considered in conjunction with my current comment for 53828 Federal Register/Vol. 91, No. 160/Thursday, August 20, 2026/Proposed Rules, which states, “As resource conditions and national policy have evolved, the Department has determined that a single, national blanket approach to the management of inventoried roadless areas taken in the 2001 Roadless Rule constrains responsible officials from exercising the timely, place-based discretion needed to meet the Forest Service’s multiple-use mission.” NOTE: While the 2001 roadless rule constrains officials from exercising their absolute place-based discretion, it does not follow such discretion is needed to meet the Forest Service’s multiple-use mission. On the contrary, NFMA was driven by management skewed to commodity production over multiple use values: watershed, wildlife, wildlands, recreation. Conditions on the Bitterroot amd the Monongahela national forest were evidence a more balanced approach was needed, resulting in NFMA. “In addition, evolving national priorities and changed conditions have required more active management approaches. The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which in turn has contributed to challenges in addressing forest health concerns.” NOTE: See pg 8 from my 2025 comments for a research being done. There are volumes that dispel lack of active management as a driver of forest health concerns. On the contrary, there is evidence forest management itself fosters such concerns. “This proposed rescission is intended to return primary authority for determining the appropriate management of inventoried roadless areas at the local level to the land management planning process mandated by the National Forest Management Act of 1976 ……The National Forest Management Act establishes the requirement for the Forest Service to develop land management plans, including direction in 16 U.S.C. 1604(a) and (b) for interdisciplinary planning and consideration of landscape-level conditions. These statutory requirements are implemented through the Agency’s land management planning framework, which require consideration of the plan area in the context of the broader landscape and requires that each plan reflects the unit’s expected distinct roles and contributions to the local area, region, and Nation. “ NOTE: Interdisciplinary planning and consideration of landscape-level conditions was done on the Flathead NF and ongoing revision on the Lolo NF. Refer to my Sept 2025 comment using Flathead as an example. Of 500,000 roadless acres, fewer than 200,000 remained. The rest were assigned management areas based on conditions and public input. Decision-makers balanced conflicting uses and devised management area prescription for roadless areas. “At the same time, this planning approach allows for place- based, collaborative decisionmaking that is responsive to specific on-the- ground resource conditions, rather than a ‘‘one-size-fits-all’’ national mandate. While national-level considerations are important, land management planning efforts by local decisionmakers at the national forest or regional scale are best positioned to make decisions about inventoried roadless areas because they understand the unique ecological, economic, and social needs of their communities.” Note: Yes, this is being done for revisions under the 2012 planning rule. Ironically, the Roadless Rule Recission is itself a blanket one-size-fits-all mandate that the rule dispesl. I requested the DEIS disclose forests that have done plan revisions, those in the process, and those not started. Only those that have not started could be subject to the recission. Those completed or undergoing revisions have engaged in place-based, collaborative decision-making responsive to on-the-ground conditions. The DEIS fails to respond to my request.

Continued: 4. Fire is a part of the ecosystem. To the extent that the rationale is reducing fire, the rationale is wrong, as other commenters have pointed out and as the rationale points out, that more roads lead to more fire activity. But also the entire proposal is misplaced — because the most effective way to address fires of increasing intensity is to address climate change. That is the real national priority that needs to be addressed that the government is completely failing to address. Roads in forests are not a recognized wild-land fire management policy, as other commenters have pointed out. *** Put simply, the repeal of the Roadless Rule is a step backwards in public lands management. It effectively takes public lands out of the hands of the people they are set aside for — the American public — and hands them to special interests who are willing to pay for them. This is not the mandate that the USFS has been given by Congress. The mandate is the manage these lands for multiple uses. Creating new roads in forests prioritizes only one use, timber harvesting, over all others. *** My experience in this comment is drawn from recreating at the following USFS properties: Little Missouri National Grassland; Buffalo Gap National Grassland; BigHorn National Forest; Chequamegon-Nicolet National Forest; Hiawatha National Forest; Ottawa National Forest; Huron-Manistee National Forest; Superior National Forest; Chippewa National Forest; Shoshone National Forest; Custer-Gallatin National Forest; Flathead National Forest; Bridger-Teton National Forest; Caribou-Targhee National Forest; Gifford Pinchot National Forest; Olympic National Forest; Okanogan-Wenatchee National Forest; Mount Baker-Snoqualmie National Forest; Colville National Forest; Medicine Bow-Routt National Forest; Arapaho National Forest; White River National Forest; Black Hills National Forest; Thunder Basin National Grassland; Unit-Wasatch-Cache National Forest; Sierra National Forest; Stanislaus National Forest; Lincoln National Forest; and Shawnee National Forest. My major takeaway from all these experiences is that these Forests already have more roads than most people could explore in a lifetime. There is quite simply no practical or logistical need, from a recreational perspective, for more under the rationales that the USFS has proposed in this rule change.

I am writing to oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. Our roadless national forests are some of the last truly wild places left in this country. They are special because they have stayed undeveloped. Once roads are built, the land changes for good. Logging, mining, and heavy traffic follow, and the quiet, the clean water, and the wildlife habitat that make these places unique can’t be restored. I have spent my own life exploring these lands, from Flathead National Forest to Big Bear to Shoshone and Gallatin to Shasta/trinity, etc. these are incredible places. Experiences there shaped who I am, and I want my children, grandchildren, and every future American to have the same chance to find them as I did. These forests belong to all of us, not just to the present generation. Keeping them roadless is a promise to the people who come after us. I urge the Forest Service to keep the Roadless Rule in place and protect these lands as they are today.

As a professional ecologist, researcher and educator, I am writing to most strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Roadless Rule). I urge the Forest Service to retain the current Roadless Rule by selecting Alternative 1 and for the Forest Service to reject the proposed nationwide rescission under Alternative 2 as well as any alternative that substantially weakens protections. I am deeply concerned about the false claim that removing the Roadless Rule is necessary to reduce wildfire risk. On the contrary, 96.2% of fires start within 800 meters of a road (Pacific Biodiversity Institute). It is clear that more roads mean more fires, and my studies of areas opened to roads show that among other things, all of this equipment being brought in spreads non-native plants which have no part in the ecosystem to manage them, which takeover and suffocate the diversity of native flora and create massive amounts of highly flammable ground fuels. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes. Wildfire risk reduction should not be used as a blanket justification for expanding roads and resource extraction into millions of acres of pristine, roadless wildlands. I am also very concerned about the proposed rescission emphasizing greater local decision-making authority in forest planning processes. The Roadless Rule was established in part due to the failure of local forest planning process to maintain ecological, cultural, and public values of roadless areas to an adequate level across the National system. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the National Forest System. Returning these decisions to entirely local planning processes should not be treated as a substitute for consistent nationwide protection measurements. Putting these forests under local control would have immense impact on the land managers' ability to protect undeveloped wildlands put wildlife habitat and connectivity, biodiversity, endangered and threatened species and clean water which emerges from the headwaters in many of these roadless areas at grave risk. We must keep all roadless wildlands under protection at the National level. As a researcher on biodiversity preservation on National Forest lands, I have an intimate knowledge of roadless areas in the Flathead National Forest as well as the Allegheny National Forest and have conducted biodiversity surveys in both locations as well as in non-roadless areas on both these National Forests. It is profoundly clear from all the studies that the the way lands are managed in non-roadless areas results in a far less biodiverse ecosystem that includes huge numbers and in some areas, monocultures of invasive, shallow rooted flora which create highly flammable ground fuels, decreasing water retention in dry soils, increasing wildfire risk and suffocating the diversity of native flora which support the entire ecosystem of flora, fauna and fungi. The 2001 Roadless Area Conservation Rule should be kept intact as is with no changes whatsoever. We cannot afford to lose any more of the scant amount of pristine wildlands we have remaining to hold ecosystems intact - for the wellbeing and sustenance of nature and therefore humankind.

Secretary Rollins, I am writing as a first year college student majoring in Environmental Science, and I’m an avid member of my university’s outdoors club. This summer, my best friends and I travelled to Flathead National Forest in Montana and spent a week there under the stars, in the deep woods, surrounded by the most abundantly growing nature I have ever seen in my life. Those memories are irreplaceable, and I have never felt so connected to the people I love most and the Earth I live on. The decision to rescind the Roadless Rule of 2001 would remove protections from almost half a million acres of Flathead National Forest and 45 million nationwide. This cannot happen. The allowing for roads and logging in these protected areas would serve no benefit to the lands and do nothing but cause further irreparable damage to the environment. It is, quite frankly, disgusting that this proposal has been justified as ‘protecting our forests.’ This will not decrease wildfire risk. In actuality, a 2026 study found that wildfires are four times more likely to start nearby large roads than in roadless areas because most wildfires are caused by humans. Roads will not lead to the better management and protection of wildlife and will instead disrupt, harm, and displace the 250 species of animals in the Flathead forest alone— not to mention how logging would also impact these delicate ecosystems. Roads divide up natural areas, creating barriers that most species won’t cross. The ones that do may join the million of vertebras that are made roadkill each day in the US. There will be devastating ecological consequences, and it is deplorable for this rescinding to occur under the guise of conservation. Imagine this destruction on a larger scale, and it is a large, large scale. Imagine these diverse landscapes that make our country beautiful, imagine these precious memories I carry, and imagine them all over the country. That is what the land represents. Our national forests hold memories and truth. They hold 3000 animal species, 400 of them endangered, tens of thousands of kinds of insects and fungi, and 60 billion metric tons of carbon from the atmosphere. These are places to be protected, not to be left vulnerable. This is for the sake of our great national forests and for the sake of our own humanity. Do not rescind the Roadless Rule. Reference Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2

1. Rescinding the Roadless Rule will accelerate the already increasing frequency of wildfires rather than contribute to fire mitigation measures as stated in the Proposal. Increased roads will mean increased wildfires; this has been demonstrated on multiple occasions by peer-reviewed research. Ninety percent of wildfires are caused by humans, and 95% of those fires are within one half mile of a road. The reasons for this are many and include discarded cigarettes, campfires, fireworks, equipment malfunction, vehicle-caused sparks, and alteration of the vegetation to more flammable varieties. A recent peer-review article (Aplet, G.H., Hartger, P., & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecol. 22, 8 (2026). https://doi.org/10.1186/ s42408-026-00450-2) presents data supporting the widely recognized fact that increased roads translate into increased wildfires. Additionally, USDA analysis of wildfires during the decade 2014-2024 shows that only 8.7% of roadless lands burned during that period compared to 14% on other federal lands. The present Rule already allows for fire mitigation treatments; in fact, 34% of all fuel treatment activities between 2001–2019 occurred in roadless areas. Thus, the claim articulated in the proposal that the Rule constrains fire mitigation is untrue. This claim has been suggested as the main rationale for rescinding the rule but is in fact inaccurate and has no functional application. 2. The forests in roadless areas are generally not suitable for timber production. These forests are in remote, steep areas with rocky terrain, making construction of road access difficult, costly, and hard to maintain. The majority of the timber that would be available if new roads were built to access the present roadless areas is frequently of low quality and would require extensive and expensive haul times. This is particularly true on our local forest, the Flathead National Forest (FNF), where proposed timber sales have failed to attract successful bidders; selling only after dramatic reductions in minimum bid price (https://hungryhorsenews.com/news/ 2025/jul/23/expect-more-timber-harvest-on-flathead/). 3. New roads will unavoidably be poorly maintained. Presently, the USFS is responsible for many more miles of road than the Federal Highway Department. They cannot keep up with present road maintenance needs due to staff and budget constraints, with a reported $8 billion maintenance backlog. Currently, the cost of maintaining the 368,000 miles of USFS roads is estimated to be $1.6 billion. In 2025, Congress appropriated only $73 million to road maintenance, roughly 0.5% of the estimated need. This is apparent on the Flathead National Forest, where poor road conditions are a persistent barrier to public access for recreation or to private property contiguous with the USFS lands. 4. Recreational and municipal water supplies would be threatened. Roads threaten water quality by causing increased sediment runoff. This, in turn, endangers municipal water supplies. Increased sediment runoff from roads reduces water storage capacity upstream from municipal systems, resulting in the need for expensive system upgrades. This sediment also threatens local fisheries, including the endangered bull trout and native cutthroat trout. 5. Roads threaten the populations of both endangered species and species important to recreational hunting and fishing. This has been documented in numerous scientific studies. As noted above, roads negatively impact fisheries. Native fish are critical to the local outfitter and guide industry; threats to these fisheries in turn threaten the local economy. Populations of other species important to recreational pursuits such as hunting and wildlife viewing have been to be diminished by roads. These include wolves, grizzly bears, mule deer, cougars, bighorn sheep, and moose. Amphibians, reptiles, and migrating songbirds are also negatively affected. Increased roads will also encourage the spread of invasive species. 6. More open roads will mean more motorized recreational access. This is a poorly policed industry which has caused fatalities in the North Fork of the Flathead River Valley. Recent reductions in agency capacity will further limit law enforcement needed to police increased motorized recreation. This is complicated by the recent explosion in motorized recreation as a result of newer technology designed for on- and off-road use. These technologies threaten riparian habitat and the opportunity for quiet recreation at a time when law enforcement is already compromised.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My property borders the Flathead National Forest. I go there because it is quiet and not overrun with people. I paddle Tally Lake, Flathead Lake, and Whitefish Lake. These places matter to me, and this administration's proposal to rescind the 2001 Roadless Area Conservation Rule would damage them in ways that cannot be undone. Our public lands should be managed for conservation, not extraction, which is all this administration seems to care about. The Roadless Rule reflects a straightforward commitment: some country stays intact. Rescinding it abandons that commitment without a credible reason. The agency's own record undermines its wildfire rationale. The agency has previously 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 proposal does not explain how it departs from that finding. I ask that the agency reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain that departure in plain terms that the public can evaluate. The economic case for rescission is just as weak. The agency has acknowledged 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 that, 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. The agency cannot establish a net benefit on its own numbers. It is also already $6.9 billion behind on maintaining the roads it has, with a road budget of about $73 million a year. It would be far better if tax dollars went to something other than projects no one wants or needs. The agency must explain on the record how opening new roadless country to development is justified when its own analysis cannot show the action pays. The Flathead National Forest is already over logged. We see it at the end of every winter. When you cut down most of the trees and do not leave enough buffer, what survives cannot stay standing or hold up to wind. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. More roads into this landscape means more sediment, more damaged streams, and more water quality problems downstream. I expect the agency to address that relationship directly and explain what specific protections, enforceable ones, would prevent that outcome here. The state-by-state approach this proposal favors has been tried and rejected. The record reflects 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 agency has previously found that local decision-making can incrementally reduce nationally significant roadless values. How does this proposal avoid repeating the deficiencies the Ninth Circuit identified the last time the agency replaced the national rule with a state-by-state approach? The agency must answer that question on the docket. Finally, the proposal argues that the 2001 rule exceeded the agency's statutory authority. Courts that examined that question reached the opposite conclusion. One court found, after full review: "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 upheld the 2001 rule as within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held it did not create de facto wilderness. The agency must state plainly what legal basis it relies on in departing from those holdings. I oppose this rescission. The Flathead country I border and paddle is worth protecting, and the agency has not made the case that rescission serves the public interest. Sincerely, Julie Sebby Whitefish, MT

I live in Portland OR and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking and camping. I love the peace and quiet of undeveloped forests. Whitefish Divide is one place that has shaped my views on this proposal. It is within the Thompson Seton #483 Inventoried Roadless Area in Flathead National Forest. This place is amazing - so peaceful! I am concerned about how USDA is weighing wildfire, management flexibility, and the effects of increased access. Providing human access to these forests by building roads increases the risk of fire. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.I live in Portland OR and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking and camping. I love the peace and quiet of undeveloped forests. Whitefish Divide is one place that has shaped my views on this proposal. It is within the Thompson Seton #483 Inventoried Roadless Area in Flathead National Forest. This place is amazing - so peaceful! I am concerned about how USDA is weighing wildfire, management flexibility, and the effects of increased access. Providing human access to these forests by building roads increases the risk of fire. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? I live in Portland OR and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking and camping. I love the peace and quiet of undeveloped forests. Whitefish Divide is one place that has shaped my views on this proposal. It is within the Thompson Seton #483 Inventoried Roadless Area in Flathead National Forest. This place is amazing - so peaceful! I am concerned about how USDA is weighing wildfire, management flexibility, and the effects of increased access. Providing human access to these forests by building roads increases the risk of fire. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments. For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in Missoula, Montana and have been privileged to live/explore roadless areas in Northern Idaho, the Western Slope of Colorado and in Southern New Mexico. I many of my fondest memories with family and friends have been in roadless areas like fishing/floating in the Flathead NF/Bob Marshall Wilderness, hunting and berry picking in Lolo NF and mountain biking regularly in the Rattlesnake RA. Wild places like these are irreplaceable. From a financial standpoint, there is strong evidence showing there isn't a budget to maintain mind-boggling number of existing roads on public land. Further, I worry that that more roads lead to higher incidences of devastating human-started forrest fires. Please support Alternative 1 (no action alternative). Thank you for considering my comment. Cody Goss

My home boarders Flathead National Forest in Montana, so I have a more direct relationship with this rule. I feel it is vital to protecting our public lands that we maintain the Roadless Rule. This rule decreases the risk of fires (most wild fires start close to roads) and maintains threatened habitat. Thanks! Matthew Pittman 9340 North Fork Rd Polebridge MT 59928

I live in Loveland, CO and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking, hunting or fishing, camping, wildlife watching, and living in or near a National Forest community. Roadless, undeveloped National Forest lands provide a vital, national safeguard to allow wildlife to thrive, for the wildest remaining lands in our National Forests to preserve intact wildlife habitat, clean watersheds, primitive backcountry recreation, and the wild character that makes these areas pristine and sacred. Whitefish Divide is one place that has shaped my views on this proposal. It is within the Thompson Seton #483 Inventoried Roadless Area in Flathead National Forest. Flathead National Forest is highly valued for its pristine abundant lakes, rugged wilderness, wild rivers, 2,000+ miles of trail, beautiful campgrounds, and year-round beauty. This forest is a premiere natural landscape of the American West and must be left this way, preserved for future generations and wildlife! I am concerned about the cost of expanding the National Forest road system. The Forest Service already manages more than 375,000 miles of roads and reports nearly $6 billion in deferred maintenance on roads, plus nearly $1 billion for road bridges. We already struggle under Trump to maintain the roads we have, DUE TO HIS NAT'L FOREST FUNDING CUTS! I am concerned about wildlife habitat and landscape connectivity. Large roadless landscapes will provide intact habitat and connections between protected areas for wildlife to exist. Roads will destroy and fragment habitat while increasing human access. Wildlife needs places to exist free of human encroachment! I am concerned about clean water and healthy watersheds. We need healthy, clean watersheds for fish and other river life to thrive. Roads require drainage systems, culverts, stream crossings, and ongoing maintenance. Poorly located or maintained roads will contribute sediment to streams and negatively affect aquatic habitat. Roadless areas matter to me for recreation and the experiences they provide. Roadless landscapes provide opportunities for primitive and backcountry recreation that are increasingly difficult to find in more developed landscapes. This means solitude, PEACE, and backcountry experiences that roaded areas do NOT provide. I am concerned about how USDA is weighing wildfire, management flexibility, and the effects of increased access. The Roadless Rule contains exceptions that allow road construction in certain circumstances, when needed to protect public health and safety. Roads can facilitate firefighting/management access, but increased human access WILL create more frequent opportunities for wildfire ignition. Human caused wildfires! I am concerned about increased timber-development pressure in currently roadless areas. Rescission would return greater authority over road construction, reconstruction, and timber harvest to Forest Service planning and project-level decisions at a time when the administration has directed the agency to increase timber production. GREED at the expense of wild places & wildlife! I believe maintaining a national conservation baseline matters. FOR 25 YEARS, the Roadless Rule has established a national baseline while still containing exceptions for particular circumstances. Rescission would shift more decisions to forest plans and individual projects. HANDS OFF OUR PUBLIC LANDS! OVER 95% OF AMERICANS HAVE SUBMITTED PUBLIC COMMENTS TO OPPOSE AND CONDEMN RESCINDING THE ROADLESS RULE -- LISTEN TO THE AMERICAN PEOPLE. THESE ARE OUR PUBLIC LANDS. THEY BELONG TO THE PEOPLE, NOT TO GREEDY TIMBER LOGGING, MINING, AND O&G DEVELOPERS! NOT TO THIS ADMINISTRATION UNDER TRUMP! Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

**Re: Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66)** To the U.S. Department of Agriculture and U.S. Forest Service: I am writing as a resident of Columbia Falls, Montana, to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. My family lives near the Flathead National Forest, where we regularly enjoy the extraordinary natural landscapes and wildlife that make northwest Montana such a special place. We believe these public lands should be protected not only for those of us who live here today, but also for future generations. The Roadless Rule provides important protections against road construction, road reconstruction, and certain timber harvesting activities in inventoried roadless areas. Removing these nationwide safeguards raises serious concerns about habitat fragmentation, increased human disturbance, and the gradual loss of our remaining undeveloped national forests. Our concerns are particularly relevant to Columbia Mountain, near our home in Columbia Falls. A private company has recently resubmitted a proposal to construct a commercial sightseeing tram on the mountain. The earlier proposal was rejected in 2022 because of conflicts with the Flathead National Forest Plan. Columbia Mountain provides valuable wildlife habitat, including habitat for grizzly bears, and contains designated roadless lands. We are deeply concerned that weakening federal roadless protections could increase development pressure on places such as this. Although rescinding the Roadless Rule would not automatically authorize this particular project, it would remove an important layer of nationwide protection. We recognize the importance of responsible forest management, including appropriate wildfire mitigation. However, we believe such activities should be carefully tailored to demonstrated needs and conducted within existing conservation protections whenever possible. The need for responsible forest management does not, in our view, justify eliminating nationwide roadless safeguards. I urge the Forest Service to consider the following concerns before making its final decision: 1. The potential for increased habitat fragmentation and disturbance to grizzly bears and other wildlife that depend on large, connected landscapes. 2. The cumulative environmental consequences of additional roads, infrastructure, and commercial activity in previously undeveloped areas. 3. The importance of maintaining consistent national protections rather than relying exclusively on individual forest management plans. 4. The possibility that removing nationwide protections will create additional pressure to amend existing forest plans to accommodate development. 5. The long-term and potentially irreversible consequences of introducing roads and permanent infrastructure into presently roadless landscapes. The economic benefits of increased development must be carefully weighed against the lasting public value of intact ecosystems, healthy wildlife populations, clean water, and opportunities to experience undeveloped natural landscapes. Once these landscapes are fragmented by roads and permanent infrastructure, restoring their original character can be extraordinarily difficult. Our national forests belong to the American people. We believe their protection should extend beyond short-term economic interests and preserve the natural resources entrusted to future generations. I respectfully request that the USDA retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative rather than proceed with the proposed rescission. Thank you for considering my comments. A concerned resident Columbia Falls, Montana

I live in seattle and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking, camping, wildlife watching, living in or near a National Forest community, and operating or working for a business connected to public lands. We need to protect wild lands from human intrusion. Please reinstate roadless rule is and keep them in effect. Whitefish Divide is one place that has shaped my views on this proposal. It is within the Thompson Seton #483 Inventoried Roadless Area in Flathead National Forest. Stunning beauty. I am concerned about wildlife habitat and landscape connectivity. There is already human damage in these beautiful lands. Let's keep humans out of the ones that are still wild. Before rescinding the national rule, I would like USDA to answer this question: How would USDA weigh the potential for roads to provide management access against the additional opportunities for human-caused wildfire ignitions that can accompany increased access? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

I live in Seattle, Washington and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking, camping, wildlife watching, and living in or near a National Forest community. Living in a city means I need to escape to nature and be truly away from roads. Whitefish Divide is one place that has shaped my views on this proposal. It is within the Thompson Seton #483 Inventoried Roadless Area in Flathead National Forest. The beauty is awe inspiring and rejuvenates my soul. I am concerned about wildlife habitat and landscape connectivity. Large roadless landscapes can provide relatively intact habitat and connections between protected areas. Roads can fragment habitat and increase human access. I am concerned about clean water and healthy watersheds. Healthy and undeveloped watersheds are important for fish, aquatic life, and the health of the forests. I believe maintaining a national conservation baseline matters. Protection for these lands should not depend on the whims of each new administration. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

I am writing as a Montana resident to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service to retain the current Roadless Rule under Alternative 1 and reject the proposed nationwide rescission under Alternative 2 and any alternative that substantially weakens protections. The DEIS stated purpose of the proposed rescission emphasizes greater local decision-making authority in forest planning processes. Yet, the original Roadless Rule was established in part due to the failure of the local forest planning process to maintain ecological, cultural, and public values of roadless areas to an adequate level. Returning these decisions to wholly local planning processes should not be treated as a substitute for consistent nationwide protective measures. As a Montanan, I am concerned about the claim that removing the Roadless Rule is necessary to reduce wildfire risk and that putting these forests under local control would have little adverse impact on the ability to protect their values as undeveloped wildlands. The DEIS recognizes that increased road construction can provide additional opportunities for wildfire response and fuels management, but it can also increase opportunities for unplanned human-caused ignitions. 96.2% of fires start within 800 meters of a road. It is clear that more roads mean more fires. Wildfire risk reduction should not be used as a blanket justification for expanding roads and resource extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes. The agency should also disclose and analyze the potential for new roads to increase suppression complexity, vehicle hazards, traffic congestion, emergency evacuation challenges, invasive vegetation, and future human-caused wildfire ignitions. Claims that road construction will improve firefighter safety should be supported by an analysis of trade-offs026.08.25 of the specific operational conditions under which new roads may provide a potential safety benefit—but also create new safety risks and hazards during suppression operations. Roadless areas provide some of the largest remaining undeveloped landscapes in the National Forest System. Removing nationwide protections could increase opportunities for road construction and logging, mining, and drilling, with impacts degrading wildlife habitat, connectivity, water, soils, biodiversity, recreation, and other ecological values. The Roadless Area Conservation Rule was initially implemented to protect the ecological values of these forests as a connected and biodiverse landscape that local control could not account for. The DEIS acknowledges that more road construction and timber harvest are reasonably foreseeable if the Roadless Rule is rescinded or revised under Alternatives 2 and 3. I am particularly concerned about the Flathead National Forest and surrounding wilderness areas. The Forest Service should not rely solely on future, site-specific project reviews to protect these values. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the National Forest System. The DEIS recognizes that additional road construction and timber harvesting could have long-term negative effects on Tribal rights and interests, including impacts to treaty-reserved resources, sacred sites, ancestral trails, and other culturally significant areas. I urge the Forest Service to ensure meaningful government-to-government collaboration and to fully incorporate Tribal knowledge and concerns before any decision is made to remove protections. New roads can also increase physical access to areas that have previously remained relatively protected from unauthorized entry, human-caused disturbance, and resource extraction. These consequences should be considered alongside direct impacts to culturally significant places and treaty-reserved resources. Future consultation on individual projects is not an adequate substitute for considering these impacts before nationwide protections are removed. For these reasons, I urge the Forest Service to retain the 2001 Roadless Rule under Alternative 1 and reject the proposed nationwide rescission, ensuring that wildfire policy is grounded in operational reality, ecological integrity, Tribal knowledge and rights, and the long-term safety of firefighters and communities.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Flathead National Forest is where I paddle, fish, hike, camp, and sit beside streams and lakes that still run clean and clear. I live in Whitefish, Montana, and access to vast forest lands—here and across the country—is not incidental to my life. Time outdoors is essential to my mental and physical health. Being able to see elk, moose, bear and other wildlife in these forests is something incredibly special, and intact roadless areas are part of what makes that possible. I strongly oppose rescission of the 2001 Roadless Area Conservation Rule. Montana alone has more than 6 million acres of inventoried roadless areas. These lands protect watersheds as well as wildlife habitat and recreation. Montana's Constitution recognizes our right to a clean and healthful environment, and I am particularly concerned about what additional roads could mean for water quality. The agency's own record documents the significant contribution roads can make to sediment from timber activities. Once a road is built and a watershed or habitat is degraded, fixing that damage can be difficult and expensive. I don't understand why we would remove a broad, longstanding protection and then depend on project-by-project review to protect these resources. If there are specific management problems with the current rule, address those problems rather than eliminating the rule altogether. I am also concerned about wildlife. The agency's own analysis recognizes the effects roads can have on elk, moose and grizzly bears, including habitat avoidance, increased human-wildlife interaction and increased risk of mortality. These aren't theoretical concerns in northwest Montana. These are the animals that live in the forests around my community and one of the reasons these places are so valuable. I also question the wildfire rationale for rescission. 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." If increased access is being presented as necessary for wildfire management, the agency should clearly reconcile that argument with its own data on human-caused ignitions. The economic argument deserves the same scrutiny. The agency's analysis has previously shown that timber affected by the rule represents less than 0.5% of U.S. production and oil and gas production from all National Forest System lands represents about 0.4% of national production. Those are relatively small national economic contributions compared with potentially permanent impacts to watersheds, wildlife habitat and recreation—and the added cost of maintaining more roads. I recognize that our forests need to be managed. I support responsible forest management, wildfire mitigation, access and appropriate economic use of public lands. But those needs do not convince me that we should eliminate protections across millions of acres. The Roadless Rule already contains exceptions, including provisions addressing public health and safety. If those exceptions are inadequate, the agency should identify specifically what cannot be accomplished under the existing rule and address those needs directly. This does not need to be an all-or-nothing choice between managing our forests and protecting them. Targeted changes, based on science and demonstrated need, make far more sense to me than removing the Roadless Rule nationwide. I urge the Forest Service to withdraw the proposed rescission and retain the Roadless Area Conservation Rule. Sincerely, Julie A. Raine Whitefish, Montana

I'm opposed to the proposed rescission of the Roadless Rule. Among the affected areas, I have hiked and camped in the Lewis and Clark National Forest and the Flathead National Forest in Montana. While destroying and diminishing opportunities for public recreation such as hiking and camping. The road building, resultant logging and other activities allowed through the proposed rescission will destroy or significantly impact habitat for federally listed species including Grizzily Bear, Canada Linx, Bull Trout and Gray Wolf. Game and non-game species will also suffer significant direct and indirect negative impacts. I have also hiked and camped in national forests in Colorado, Idaho, Utah, and Wyoming which will experience similar losses of public recreation opportunities along with the habitat destruction and degradation to federally listed species as well as other non-game and game species described in the previous paragraph. The 2001 Roadless Rule should stay in place! Thank you The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

Dear Secretary Rollins, I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I urge the Forest Service to adopt Alternative 1, the No Action alternative, and keep full Roadless Rule protections in place. I live in the Flathead Valley of northwest Montana, and my family owns a outdoor recreation company. Wild country is a big part of why people live here, visit here, and spend money here. About 6.4 million acres of Montana's national forests, roughly 37%, are Inventoried Roadless Areas. Alternative 2 would strip protections from all of it, and Alternative 3 would still open much of it to new roads and logging. Near my home that includes the northern Swan Range and the Jewel Basin Hiking Area, the Whitefish Range west of the North Fork Flathead, the Middle Fork Flathead, the Badger-Two Medicine, and the roadless country bordering the Cabinet Mountains Wilderness on the Kootenai. Wildlife. The DEIS says rescission would "adversely affect" 327 threatened and endangered species and 71 designated critical habitats. In northwest Montana that means grizzly bears, Canada lynx, wolverine, and bull trout, all federally listed and all dependent on large, unfragmented landscapes and cold, clean water. The Swan and Whitefish ranges link Glacier National Park to the Bob Marshall Wilderness complex. How will the agency keep secure grizzly habitat and that connectivity intact once new roads go in? Water. The DEIS states that roadless areas "typically have good water quality due to limited disturbance" and that "road construction and native surface forest roads are the largest source of sediment related to timber harvest operations." These headwaters feed the Flathead River and Flathead Lake, and Wild Montana estimates about a third of Montanans get drinking water from roadless watersheds. Sediment is especially damaging to bull trout spawning streams. How will the agency prevent erosion and sedimentation in these watersheds without the Rule? Fire. The DEIS admits that "road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions." Studies have found fires are four times more likely to start near a road than in a roadless area. Northwest Montana already lives with long smoke seasons. Adding roads to remote country adds ignition points. Cost. The Flathead National Forest already has about 3,500 miles of road and maintains only about half of them. The national deferred maintenance backlog is over $6.9 billion, and the DEIS says new roads could be built across 18.2 million acres in the short term. Much of Montana's roadless land is steep, high-elevation ground with little commercial timber value. Building roads there leaves taxpayers with a bill and little to show for it. The DEIS also projects a $9 million annual loss in visitor spending in local communities, and Montana towns like ours depend on that spending. Process. More than 600,000 people commented last fall, and over 99% opposed rescission. The DEIS notes that "the majority sentiment among Tribal governments consulted is opposition to the proposed rescission," which matters here given the Badger-Two Medicine's importance to the Blackfeet Nation. A decision this large should not be rushed through shortened comment periods. For these reasons, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a serious mistake. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative. Sincerely, C Quinn Kalispell area, Montana

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001. 50 years living in NCDE & Yellowstone Region has given me solace based in truth so cannot tolerate rescission in exchange for marketization of public lands. RR means protections not their removal.RR lands mean connectivity for species survival. Rescission displaces threatened species. ESA listed grizzly bear requires best science. Rescission shuns it and will prove fatal for grizzly populations. Cited lands mirror grizzly DPS compliance. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, specifically inventoried RR areas: Lost Water Canyon (9,251 acres), Custer NF, MTBurnt Mountain (10,698 acres), Custer NF, MT Black Butte (871 acres), Custer NF, MT Red Lodge Creek Hellroaring (17,210 acres), Custer NF, MTOkanogan-Wenatchee NF (1,006,000 acres), Okanogan NF, WAGifford Pinchot National Forest (213,000 acres), Gifford Pinchot National Forest, WAMt. Baker-Snoqualmie NF, WALiberty Bell (108,495 acres), Okanogan NF, WACuster Gallatin NF (848,000 acres), Custer Gallatin NF, MTBob Marshall Wilderness Complex (1,483,000 acres),Bob Marshall Wilderness Complex, MT Paine Gulch (7,875 acres), Lewis & Clark NF, MTMt. High (33,484 acres), Lewis & Clark NF, MTMcgregor - Thompson (27,211 acres), Lolo NF, MTDeep Creek (7,669 acres), Lolo NF, MT Trout Creek (30,851 acres), Kootenai NF, MTCataract (9,442 acres), Lolo NF, MTBlue Slide (17,505 acres), Wenatchee NF, WA Mt. Baker-Snoqualmie NF (415,000 acres), Mt. Baker-Snoqualmie NF, WA , Okanogan NF,Pasayten Rim (17,074 acres), Okanogan NF, WASawtooth (15,693 acres), Lewis & Clark NF, MTwin Sisters (13,051 acres), Colville NF, WA Bridger-Teton National Forest (1,417,000 acres), Bridger-Teton National Forest, WyWest Pioneer (248,631 acres), Beaverhead-Deerlodge NF, MTBear - Marshall - Scapegoat - Swan (344,022 acres), Lewis & Clark NF, MT Bob Marshall-Scapegoat-Swan (334,275 acres), Flathead NF, MT East Pioneer (145,082 acres), Beaverhead-Deerlodge NF, MTWest Big Hole (133,563 acres), Beaverhead-Deerlodge NF, MTMadison (127,859 acres), Gallatin NF, MTSelway-Bitterroot (114,953 acres), Bitterroot NF,MTHoodoo (105,162 acres), Lolo NF, MTAllan Mountain (104,184 acres), Bitterroot NF, MTSnowcrest Mountain (97,649 acres), Beaverhead-Deerlodge NF, MT Freezeout Mountain (97,305 acres), Beaverhead-Deerlodge NF, MT Middle Mtn. / Tobacco Roots (96,487 Beaverhead-Deerlodge NF, MTTuchuck (17,730 acres), Flathead NF, MTThompson Seton (52,235 acres), Flathead NF, MTMt. Henry (13,603 acres), Kootenai NF, MTOlympic National Forest (86,000 acres), Olympic National Forest,WASapphires (66,619 acres), Beaverhead-Deerlodge NF,MTBear Creek (8,123 acres), Beaverhead-Deerlodge NF, MT MTLittle Bighorn (133,949 acres), Bighorn NF, WyoSleeping Child (x1074) (21,433 acres), Bitterroot NF, MT, Bitterroot NF, MTDry Canyon Breaks (4,821 acres), Colville NF, WANorth Absaroka (21,063 acres), Custer NF, MTCrazy Mountain (82,093 acres), Gallatin NF, MTBridger (45,059 acres), Gallatin NF, MTHyalite - Porcupine - Buffalo Horn Wilderness Study Area (143,991 acres), Gallatin NF, MTGallatin Fringe (51,571 acres), Gallatin NF, MT Cabin Creek Wildlife Management Area Ocd (35,048 acres), Gallatin NF, MTWAHellgate Gulch (16,821 acres), Helena NF, MTBig Snowy Mountains Wsa (88,003 acres), Lewis & Clark NF, MTCastle Mountains (29,409 acres), Lewis & Clark NF, MT Crazy Mountains (24,942 acres), Lewis & Clark NF, MT Box Canyon (12,584 acres), Lewis & Clark NF, MT- Big Snowies (9,258 acres), Lewis & Clark NF, MT North Fork Smith (8,444 acres), Lewis & Clark NF, MT Tenderfoot - Deep Creek (85,614 acres), Lewis & Clark NF, MT Eagle Park (5,912 acres), Lewis & Clark NF, MT- Calf Creek (10,108 acres), Lewis & Clark NF, MT- Pilgrim Creek (44,608 acres), Lewis & Clark NF, MT Highwood Baldy (15,305 acres), Lewis & Clark NF, MT Highwoods (24,378 acres), Lewis & Clark NF, MT- TW Mountain (8,388 acres), Lewis & Clark NF, MT Granite Mountain (10,338 acres), Lewis & Clark NF, MT Lewis & Clark NF, MT Middle Fork Judith Wsa (81,131 acres), Lewis & Clark NF, MT Bluff Mountain (38,060 acres), Custer NF, MtLine Creek Plateau (24,825 acres), Custer NF, MT, Custer NF, Mt Shoshone NF, WyoWilderness Study Area (51,961 acres), Targhee NF, Wyo- West Slope Tetons (47,448 acres), Targhee NF, Wy- Silver King (64,289 acres), Beaverhead-Deerlodge NF, Montana, - Selkirks (95,967 acres), Idaho Panhandle NF, Idaho-Grizzly Peak (7,441 acres), Kootenai NF, Montana I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects threatened species and of climate change.I ask that the agency respond to each of them.I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Dan Sullivan Chanhassen, MN

I am a Montana resident living on the Blackfeet Reservation, near the Lewis and Clark National Forest, Flathead National Forest and the Wild & Scenic Middle Fork of the Flathead River. I strongly oppose rescinding the 2001 Roadless Area Conservation Rule. I value our roadless lands because they protect wildlife habitat, clean drinking water, and the intact landscapes that make our nation special. These places are not simply undeveloped land—they are important ecosystems that support communities, wildlife, and future generations. I am particularly concerned about the potential impacts on the Badger-Two Medicine. The Badger-Two Medicine is a place of profound cultural and spiritual importance to the Blackfeet people. It contains traditional cultural resources, sacred places, and areas connected to Blackfeet cultural practices and gathering. Management decisions affecting these lands should recognize that their significance extends far beyond their potential value for timber, roads, or other extractive uses. I am also concerned about the effects of additional roads and development on wildlife habitat and water resources. Roadless landscapes can provide large, relatively intact areas for wildlife and can help maintain connected habitat. Roads can fragment habitat, increase human access and disturbance, and affect soils and waterways. Clean drinking water is a public resource that Montana communities depend upon, and protecting intact watersheds should be a fundamental consideration in federal land management. I understand that the Forest Service is considering wildfire risk reduction, forest management, and local decision-making as reasons for rescinding the Roadless Rule. Those concerns deserve consideration, but rescinding a nationwide protection is a much broader action than addressing specific forest-health or wildfire-management needs. The Forest Service should evaluate whether those objectives can be achieved through carefully targeted management while retaining protections for the ecological, cultural, and water-resource values of roadless areas. Please retain the 2001 Roadless Rule and protect these irreplaceable Montana landscapes for present and future generations. Thank you for considering my comment.