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As a resident of southwest Montana I use and benefit from roadless areas regularly and thus I oppose rescinding the roadless area conservation rule. I most regularly visit the roadless areas on the Custer-Gallatin National Forest to hunt, hike, and camp. The allure of these areas also brings a lot of money to our local businesses and economy. The roadless rule has conserved some of our nation's most intact fish and wildlife habitat for 25 years. It protects critical water resources and offers outstanding backcountry recreation opportunities. I feel that Secretary Rollins' statements on how recission would reduce wildfire risk, open vast timber resources, and improve recreation opportunities for the American public are unsupported. The Forest Service's own DEIS does not support these claims, but rather highlights research on how wildfire ignitions increase with greater road access and the timber value is way less than the cost to remove it. We also need to remember why the roadless rule was developed in the first place--there is a $10.8 billion backlog of deferred maintenance on some 370,000 miles of road. I support science-based forest management to address wildfire risk, forest health, and responsible access but rescinding the roadless rule is not the answer. Roadless does not mean unmanaged, and the current rule allows flexibility to address hazardous fuels reduction, grazing, hunting, fishing, and recreation. These multiple uses are important to many Americans! Please keep roadless areas wild so that future generations may experience that wildness and all that it offers as wildlife habitat and recreational opportunity.

I oppose the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule. I grew up in Jackson Hole, Wy and now live in Montana and use public lands all the time to hike, climb, raft, and explore the lands that have been protected so that people can use them for exactly that reason and I could not imagine a world where I let alone everyone else no longer has access to these lands. Being able to recreate in the Custer Gallatin National Forest and the Bridger-Teton National Forest is very important to me. These areas also provide vital habitat for threatened and endangered species, and the rest of the wildlife living there that would no longer have an intact habitat if busy roads were built in areas that are currently Inventoried Roadless Areas (IRAs) that would no longer be protected if the 2001 Roadless Area Conservation Rule is rescinded. The areas also protect critical municipal watersheds and clean drinking water for Americans, which would be harmed by rescinding the rule. In addition to this the U.S. Forest Service already has nearly $9 million of agency wide maintenance backlog, and building more roads would strain public funds. Additionally claims that repealing the rule would lower wildfire risk are contradicted by studies that show more roads frequently increase human caused wildfires.

I am opposed to repeal of the roadless rule because I frequently recreate in National Forests that will be effected and recreation with the current amount of roads is completely sufficient to fulfill more than a lifetime of recreation in these places. It is worth noting that I often recreate in my overlanding vehicle, which is a 2021 Chevrolet Silverado 2500 with an AT Overland Atlas camping topper that is specifically designed for overloading, which is exploring backcountry roads (primarily in national forests) and camping. I often string together trips of 2-5 days overloading in various national forests. (I will provide my experience doing so at the end of this comment.) Due to the plethora of road options already available in National Forestland, which is enough to satisfy a lifetime of use, the addition or more roads is not a compelling rationale for this proposal. Specifically, these are the reasons I am opposed to repeal of the roadless rule. 1. Impact on nearby National Parks: National Forests play a critical role in the National Park System by often surrounding National Parks and thus serving as a buffer between pristine parkland and wilderness areas and human activity. This is the case for nearly all the major parks in the park system, including the Crown Jewels of the National Parks Service, which will be directly impacted by the recession of the roadless rule—Yellowstone, Grand Teton, Glacier, Mount Ranier, Yosemite, North Cascades, Olympic, Everglades, Grand Canyon, Rocky Mountain, Sequoia and Kings Canyon, Redwood, Crater Lake, Shenandoah, Wrangell St. Elias, and Great Smokey Mountains. It is additionally the case for lesser known, but still important, national parks such as Theodore Roosevelt, Badlands, Guadalupe Mountains, Lassen, Pinnacles, Voyaguers, Mesa Verde, Black Canyon of the Gunnison, New River Gorge, as well as other national park units such as Pictured Rocks National Lakeshore and Sleeping Bear Dunes National Lakeshore. The impact on the Greater Yellowstone Ecosystem looks particularly acute. The GYE, which includes Yellowstone National Park, Grand Teton National Park, and several impacted National Forests — Custer-Gallatin NF, Shoshone NF, Bridger-Teton NF, Caribou-Targhee NF. Like the other National Parks mentioned above, Yellowstone greatly benefits by being completely surrounded by National Forest land. In fact, also like many of these other National Parks, it is impossible to enter Yellowstone without passing through a National Forest. Simply put — increasing roads and industrial motor vehicle traffic in national forestland will adversely impact the ability of people to get into the parks and will have an adverse effect on nearby wildlife and wilderness areas. 2. Impact on last remaining intact ecosystems Personally, when I camp and backpack, I do it in an intact ecosystem. Whether in/around Yellowstone, Tongass NF, Chugach NF, Superior NF / Boundary Waters, or other roadless wilderness areas, these areas are few and far between and provide solitude that is simply unavailable in forestland that permit roads. The personal benefits to me, my family, and my friends are significant. These areas provide time and space and silence for personal reflection and personal growth. Adding additional roads into roadless areas threatens this recreation. It is also worth noting that these areas are some of the last areas WITHOUT ROADS in the world, so the only areas that permit space for reflection away from modern society. These areas need to be preserved as is for this unique and limited experience. The estimated loss of $6.1M annually is a ridiculous underestimate that completely lacks support. The real total is far greater. 3. No definition of the “regulatory burden” that will allegedly be relieved. There is no real definition of what the exact “regulatory burden” that USFS claims is present. If this is just another way of stating that this current government just doesn’t like the rule, then that is not a persuasive reason to repeal it. Moreover, the rationale is full of vague, undefined justifications that do not hold up to scrutiny: - “Constrains responsible officials from exercising the timely, place-based discretion…” - “Evolving national priorities and changed conditions…” - “Removed important management tools for key areas…” - “Unique ecological, economic, and social needs of their communities…” These are vague, boilerplate terminologies for which no concrete examples are given in the rationale. Indeed, there are no examples given of any local forest service officials expressing desire for more “flexibility to address conservation and resource issues” by repealing the roadless rule. Absent any examples, the rationale for this repeal cannot stand. (To be continued - 1 of 2)

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.

Comment on RIN 0596-AD66: Retain the 2001 Roadless Area Conservation Rule I urge the Department to withdraw this proposal and keep the 2001 Roadless Rule in place. My connection to these lands spans the country. I lived in Vermont, where the Green Mountain National Forest holds the largest roadless areas in the state. Those intact hardwood forests protect clean water and wildlife in a region where wild land is scarce. My family owns property in Montana just outside Yellowstone, next to the Custer Gallatin National Forest. Its roadless lands are part of the connected habitat that grizzly bears, elk, and other wildlife use to move across the Greater Yellowstone ecosystem. Breaking that habitat up with roads would harm the very thing that makes the region extraordinary. And as an avid explorer of Wisconsin's parks and forests, I value the roadless areas of the Chequamegon-Nicolet as some of the last undeveloped forest in the Upper Midwest. The draft EIS does not adequately analyze how new roads would fragment wildlife corridors or degrade headwater streams. It also fails to account for the economic value these areas bring to nearby communities through recreation and tourism, value that depends on their staying wild. These protections took years of public process and more than a million comments to create. They should not be removed through a short comment window with no public hearings. Please retain the 2001 Roadless Rule. Maureen Gribble, Wilmette, Illinois

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The "Bob," as many of us call it, is a special place, and the word "Wilderness" in its name is not accidental. I hike and camp in western Montana, including the Bob Marshall and also the Gallatin National Forest and the Yellowstone ecosystem. I photograph landscapes, wildflowers, birds, and large mammals. My work depends on finding beauty uninterrupted by roads, cars, logging trucks, structures, or people. More roads equals less habitat and interrupted habitat. It is a fact the agency's own record confirms, and the rescission of the 2001 Roadless Area Conservation Rule cannot be squared with what the agency has already put in writing. The wildfire rationale collapses under the agency's own data. 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." The agency now proposes to open roadless areas partly on fuels-management grounds while its own draft environmental impact statement records that road presence is the single strongest predictor of human ignition. The 1,483,000 acres of the Bob Marshall Wilderness Complex and the Gallatin's 703,144 acres across 14 inventoried roadless areas sit inside this landscape. Why does the proposal depart from the agency’s own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case is just as weak. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal supply figure, the agency's own Cost Benefit Analysis projects only $5.2 to $11.4 million a year in timber revenue to the Forest Service, while booking recreation losses at a minimum of $6.1 million a year and arriving at a net present value spanning -$92 million to +$199 million. The road system being expanded already carries a $6.9 billion maintenance backlog. The Gallatin Range fight has been one of the most contentious roadless battles in the country, pitting backcountry hunters and wildlife advocates against timber interests in grizzly bear habitat, and the verified species of the Custer Gallatin include grizzly bear, wolverine, elk, and bighorn sheep. How does the agency justify expanding that road system when its own analysis cannot establish a net benefit? The wildlife consequences are documented by the agency, not invented by commenters. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, 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. The DEIS also 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. It is healing and calming to just "be" in these places, and there is research that proves this. The fauna and flora of the Bob Marshall and the Gallatin depend on roadless corridors. I want to know whether the agency will address on the record how this proposal avoids those documented harms to species its own biological assessment identifies. The legal history also matters. The record states the USDA "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency tried state-by-state substitution before and lost in the Ninth Circuit. It should explain specifically how this proposal avoids those same deficiencies, rather than simply reasserting that local approaches are preferable. Finally, the small-business certification fails on its face. 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. Montana alone holds 235 inventoried roadless areas totaling 6,395,392 acres. The guides and outfitters holding permits in the affected areas are not the national average firm. The agency should withdraw the certification and assess the actual small entities operating in these places. Rescind the rescission. Sincerely, Rebecca Sobin Missoula, Montana

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Three decades of fishing these places is the floor, not the ceiling. I want them around for the next three hundred decades, and that is why I oppose the rescission of the 2001 Roadless Area Conservation Rule. I hike across Virginia, North Carolina, Montana and Colorado to find the beautiful landscapes of this country. I have fished Ramseys Draft Addition in the George Washington National Forest several times and prefer to maintain the pristine nature of that area. Virginia holds 64 inventoried roadless areas totaling 393,682 acres, and the waters and terrain those areas protect are part of what I go looking for when I go out. In Montana I travel through country that includes the Bob Marshall Wilderness Complex, the North Absaroka area in the Gallatin National Forest, Hoodoo and Welcome Creek and Stony Mountain in the Lolo, the Sapphires and Upper East Fork in the Beaverhead-Deerlodge, and the vast connected landscapes of the Flathead and Lewis and Clark National Forests. In North Carolina the Pisgah holds Lost Cove and Wilson Creek. What I see in all of these places, and what I hope will still be there in generations that are not mine to witness, depends directly on whether this rule survives. The wildlife I look for when I am out, moose and bears and elk among them, are not incidental to this discussion. The agency's own record states that the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and that shooting, habituation and food reward all increase with the use of even secondary unpaved roads. On moose, the agency's Tribal record credits the rule's protection with the recovery of deer and moose populations by preserving old-growth winter shelter, while the draft environmental impact statement separately notes that moose are drawn to road corridors for road salt, which increases human-moose interactions and conflict. These findings are the agency's own. I ask the agency to explain, specifically and on the record, how rescission serves the survival of these animals when its own analysis identifies roads as a driver of their mortality and displacement. On the question of wildfire, which the proposal cites as a reason to rescind the rule, 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." That language is the agency's, not mine. The agency must reconcile this proposal with its own ignition data and explain why it is departing from those prior findings. On economics, the agency's record is equally candid: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own cost-benefit analysis projects timber revenue 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 ranging from -$92 million to +$199 million, all of this on top of a $6.9 billion road maintenance backlog the agency already cannot fund. How does an action whose own analysis cannot establish a net benefit justify expanding that road system? On the question of state-by-state approaches replacing the national rule, the agency's own record reflects its earlier rejection of the rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach," a position the record documents at 70 Fed. Reg. at 25,656. The Ninth Circuit reviewed that substitution and found it wanting. The agency should address on the record how this proposal avoids those same deficiencies. On statutory authority, the Tenth Circuit has already spoken. Its own words: "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 within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held that it did not create de facto wilderness. If the agency now takes a contrary position, it must state that position plainly and explain its legal basis. I oppose this rescission. The places I fish and hike, and the animals I go looking for in them, are worth more than a fraction of a percent of national timber output. The agency's own record makes that case. It should follow it. Leave public lands in public hands. It's uniquely American and deserves to stay that way. Sincerely, Jeff Zillgitt Arlington, VA

Park County Environmental Council (PCEC) submits these comments on behalf of our 500 active members and 2,600 regional supporters who live, work, and recreate in Park County, Montana. Since 1990, our mission has focused on protecting the wildlife, critical habitat, public lands, water resources, and community resilience that define the Upper Yellowstone and Shields River watersheds and the communities within them. PCEC members directly rely on and use specific Inventoried Roadless Areas (IRAs) across the Custer Gallatin National Forest. Our members regularly hike, hunt, and forage in the Crazy Mountains IRAs, depend on municipal and agricultural headwaters originating in the Absaroka Range IRAs and access backcountry recreation and outfit in the Hyalite-Porcupine-Buffalo Horn Wilderness Study Area and Gallatin Range IRAs. Any degradation of these specific roadless units directly impairs the indigenous sacred character, secured aesthetic, recreational, economic, and procedural interests of PCEC and its individual members. Park County Environmental Council stands in firm opposition to the U.S. Department of Agriculture (USDA) and U.S. Forest Service’s (USFS) proposed rule change to rescind the 2001 Roadless Area Conservation Rule and strongly advocates for the decision of Alt. 1 – No Action. PCEC specifically requests that the USDA and USFS address the following core legal, procedural, and environmental objections: Objection 1: Failure to analyze reliance interests under the APA by arbitrarily revoking two decades of established landscape protections without considering how local communities and wildlife depend on them, directly threatening Park County’s local culture, traditional ways of life, quality of life, and natural amenity economy. Objection 2: Compromising federal trust obligations, sacred site integrity, and treaty-reserved tribal resources. Objection 3: Degrading high-value natural assets driving the local amenity economy while imposing severe, unanalyzed road maintenance fiscal liabilities on taxpayers. Objection 4: Relying on an incorrect argument that rescission mitigates wildfire risk while failing to analyze reasonable alternatives under NEPA. Objection 5: Threatening the primary hydrological engine and clean drinking water infrastructure of the regional water supply and violating binding soil disturbance limits. Objection 6: Causing direct negative economic and operational impacts on local agricultural producers and forest permittees. Objection 7: Fragmenting irreplaceable wildlife corridors, disrupting Greater Yellowstone Ecosystem connectivity, and increasing mortality risks for species listed under ESA Section 7. Objection 8: Failure to analyze illegal NEPA segmentation, statutory cumulative environmental impacts under NEPA, and carbon emissions under Executive Order 14072. As established, the 2001 Roadless Area Conservation Rule preserves 851,000 acres of IRAs across the Custer Gallatin National Forest alone. Situated in the northern Greater Yellowstone Ecosystem (GYE), Park County serves as the primary year-round gateway to Yellowstone National Park. The 2001 Rule represents one of the most effective, successful, and scientifically supported conservation framework policies in modern public land management. By maintaining strict protections across IRAs, USFS safeguards the ecological integrity, headwater hydrology, cultural heritage, and amenity-driven economic foundations that sustain Park County, the Upper Yellowstone and Shields River watersheds, and the broader GYE. Rescinding the Roadless Rule and replacing national safeguards with localized, fragmented management regimes would initiate irreversible landscape fragmentation across the Custer Gallatin National Forest and beyond. PCEC submits these comments to preserve all factual, ecological, and legal challenges for administrative appeal and judicial review under NEPA, ESA, the Administrative Procedure Act (APA), the National Forest Management Act (NFMA), and the National Historic Preservation Act (NHPA). OBJECTION 1: We object to the removal of over two decades of successful landscape protection and conservation precedent and the failure to analyze reliance interests under the APA. We object because these changes directly threaten Park County’s local culture, traditional ways of life, quality of life, and natural amenity economy. This decision fails to look at how our local communities and wildlife are intertwined with and rely on these protections across the Custer Gallatin National Forest. USFS needs to directly address why its prior factual findings regarding the environmental, ecological, and watershed benefits of roadless protections are no longer valid. A full letter with explanations and references for each objection is attached. Missings files can not be uploaded due to the file limit on this platform. Please contact for any reference requests.

I am writing to strongly urge that the Roadless Rule not be rescinded or weakened in any way. Protection from roads is critical to wildlife habitat, especially of vulnerable large mammals like grizzly bears and wolves, key to maintaining water quality in our precious Western rivers, and important for providing human-powered solitude and recreation. I live within close access of the Custer-Gallatin National Forest, and current roadless regulations are needed to retain the pristine areas along the Gallatin and Madison ranges that harbor some of the largest populations of bears, moose, elk, wolves, and wolverines, among others, in the Lower 48 states. Americans from across the country come to see these magnificent animals, or come to fish our pristine rivers. Protecting these areas and their natural residents is crucial - and keeping these regions free of traffic and excessive human presence is required to keep the populations of these animals healthy and growing. Limiting easy vehicular access to such areas also restricts potential for human-caused wildfires, the impacts of which are growing each year as climate change progresses. Please leave the existing regulations in place to protect these wild areas for future generations to enjoy!

October 5, 2026 Director Ecosystem Management Coordination 201 14th Street SW Mailstop 1108 Washington, DC 20250-1124 Re: 2001 Roadless Area Conservation Rule Rescission Draft EIS - RIN 0596-AD66 Dear Director, The Custer Gallatin Working Group is a collaborative that works to develop agreements around priority areas and approaches for project work on the Custer Gallatin National Forest. The CGWG represents a wide range of stakeholder interests including County Commissioners, representatives of conservation NGOs, the ski industry, agriculture and ranching, recreation, hunters, anglers, outfitters, mining, and the timber industry. We support active and balanced approaches to public land management based on common sense, credible research and the values and priorities of the public. We support forest restoration, fire risk reduction, commercial harvesting, and timber stand improvement that can help sustain the forest products industry at the same time protect healthy wildlife populations. We also support a variety of recreational opportunities in our national forests, both motorized and quiet. And we believe the Forest Service must be fiscally responsible in recognizing their deferred maintenance backlog and the need to maintain their roads to standard. We do not see these things in conflict with one another. Based on our experiences we believe there are opportunities to strategically modify the management of Inventoried Roadless Areas, to better enable the Forest Service to increase active management in areas where it makes sense and retain protections for priority backcountry roadless areas. However, the approach to Roadless Rule modifications in Alternative 3 is not adequate. Revisions to the rule should be informed by hosting public meetings and listening to local stakeholders. Affected communities should have a say in decisions to increase access to some roadless lands, while balancing the important natural values of these lands. For example, communities should have the opportunity to apply craft locally-informed boundary adjustments that met the needs and interests of affected communities. Rescinding the rule with no public meetings and a three-to-four-week comment period is insufficient for our groups, who primarily meet monthly, to review and understand the DEIS and to craft meaningful comments that members can support. Therefore, we request the Forest Service to offer a longer comment period for this DEIS, public meetings, and other forms of stakeholder engagement. We also would suggest that instead of relying on expensive and time-consuming forest-by-forest updates to Forest Plans, that the Forest Service reconsider the merits of state-level rulemaking. A Montana Roadless Rule, guided by a non-partisan committee of scientists and forest stakeholders, could build on the good work being done through state Stewardship Agreements, the Good Neighbor Authority, and the long history and experience of collaboration occurring across the state. We know from experience that differing perspectives can find common ground on forest management when conversations are grounded in shared values and time is invested in working to build consensus. We encourage the Forest Service to reconsider its approach to this process and follow the examples set by the successful forest collaborative movement in Montana. Sincerely, John Prinkki, Chairman, Custer Gallatin Working Group

My name is Hillary Hunter. I am vehemently against the repeal of The Roadless Rule. I was born and raised in Petersburg Alaska and now live in Juneau. I have spent the majority of my life living in the Tongass National Forest. I have also hiked the Pacific Crest Trail California to Washington, going through many national forests and wilderness areas. I went to college in Bozeman next to the Gallatin National Forest. I lived up on the Kenai Peninsula for a summer in the Chugach National Forest. This is to say that my experience being an American and my vision of our country is strongly shaped by our national forest system and I have come to this opinion through hands on lived experience. Research conducted by the U.S. Forest Service has shown that nearly two thirds of fires that are human caused begin along roads. Building more roads into deeper wilderness area does the opposite of helping to prevent and fight wildfires. It creates greater swaths of high risk areas. It is also a bad faith argument to say that The Tongass needs roads to access areas of unhealthy forest that need to be logged in order to prevent wildfires. The Tongass is a rainforest and is not at risk of wildfires. It makes me, a local, wonder if the people proposing these decisions for my home are either uneducated on the areas that they manage or attempted to manipulate and lie to people. Creating roads to log The Tongass does not make sense either. It is so logistically difficult to remove logs from the forest, ship them to processing plants and distributors from this archipelago that the cost ends up being higher than the profit. Also healthy forest is essential to our economy. We need our salmon runs to not be disturbed. Damaging waterways where salmon return to spawn is bad for commercial fishing, subsistence fishing, and sport fishing which is an important part of the tourism economy. We have over 1.5 million cruise ship tourists a year with a season that only covers our short summer. This is a lot of people for such a short amount of time. They come here to see the wildlife and vast expanses of wilderness. They do not come here to see roads crisscrossing mountains and bald clear cuts. Retaining wilderness areas with no road access is required for Alaska to retain our majestic landscapes and ecosystems that both locals and visitors love. I have worked at a popular Forest Service sightseeing location on a roadsystem and one that is only accessible by boat, plane, or kayak. They both serve different purposes such as accessibility to the public and education. That is wonderful. It also means that I have seen first-hand how it impacts the health of the ecosystem. The place with no roads has next to no litter and the animals aren't harassed by thousands of people a day. It gives migrating birds to salmon to bears a place to live as they normally would in a world not shaped by humans. Places such as this have inherent value and allow us to avoid the pitfalls of sliding baseline effect. If the original is completely erased how do we know what we have lost. Places that have been heavily logged, such as Prince of Wales, have issues with deer population. The vegetation grows back too dense for deer to be able to have their fawns in the areas they would normally pick. They can't move through clear cuts with downed trees or the thick brush as it grows back. This can result in them having their fawns in locations that leave them exposed to predators and cars. Subsistence is important to people who live near national forests and in Alaska especially. There are many reasons that the Roadless Rule should not be repealed that are environmentally, culturally, and economically sound. Leave our wild places for the next generation and the ones after.

We do not need to further damage the areas that have been set aside for protection. There need to be places where natural integrity is maintained and not utilized and degraded by every available means. Maintain the Roadless Rule. I am a retired US Forest Service Reforestation Forester for the Gallatin NF. Timber harvesting can adequately provided from other NF lands and private lands. I am also strongly supportive of visitation to national forests that have the seemingly unique opportunity to enjoy some silence in these hyper times. Do NOT rescind the Roadless Rule!

Shouldn’t We Maintain Roads Before We Build More? I strongly oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This reckless action would devastate our public lands, waste taxpayer resources, and undermine the clean water, wildlife habitat, and recreation opportunities that millions of Americans depend on. I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. I live in Helena, Montana but lived in Red Lodge, Montana for a few years. The Beartooth Highway near Red Lodge is one of the highest, most scenic roads in the country - the road climbs to 10,000 feet. The reason why it's so scenic? There are no other roads. On both sides of the road, there is the Custer-Gallatin National Forest of Montana, and the Shoshone National Forest of Wyoming. If the 2001 Roadless Area Conservation Rule is rescinded, the south side of the road is open to roads. The roadless area, known for its roadless area, bringing tourists in from all over the world, is open for road building. This is some of the most pristine, high alpine ecosystem in the country, if not the world. It's bad enough one road (The Beartooth Highway) cuts through this roadless area - let's not make it more. The trails, bears, and humans who make this place home, right next to Yellowstone National Park, will thank you. When I worked for the Forest Service, I drove up and down some incredible dirt roads. Cleaning up campgrounds, completing whitebark pine and elk browse surveys, and patrolling trails for maintenance, I saw incredible sunsets, elk bugling, and rivers rushing. That is, when my eyes weren’t laser-focused on avoiding the literal canyons of potholes carved into the road in front of me. Once, I helped with a harlequin duck survey along a high, crisp, and cold river — the ducks favorite place to be. To survey, our team walked upstream five river miles, testing eDNA every few hundred yards. It was exhausting, lovely work — but the part I dreaded the most was the drive. You see, we started our survey with river waders on at exactly 7 a.m. We dropped off a car at the end of our river survey (to avoid the five miles back… in the dark). On the way to and from, the road had so many bumps, potholes, razor-sharp rocks, and at one point a loose electric wire, we barely made it past 5 mph. We inched, maneuvered, and got out of the car to make sure we didn’t drag the bottom on a rock. We joked it would have been faster to walk, but with the eDNA machine weighing more than 30 pounds, and our wet waders weighing just as much, we decided that the terrible drive was necessary. When there is now a push to rescind the Roadless Rule, an act passed in 2001 that protects 30% of Forest Service land from road building…I have to ask: why is there a push to build new roads, instead of maintaining the current ones? I imagine how much differently that survey would have gone with a different, better road – less dread of driving I’m sure, maybe more alert for the surveys, but also how many more people would have been able to access the river if the road was maintained. How many of you avoid a road because of how many potholes it has? I know I would go up to Priest Pass more often near Helena if the road wasn’t a nightmare to drive. I’m sure, if you access public lands like I do, to hunt, fish, hike or bike, you have a similar story of a terrible, bumpy, washed-out unmaintained road. Or, when the road got too bad, you had to turn around before your final destination. Better roads mean more access to public land, not more roads. Maintained, existing roads means better access to public roads, not more roads we can’t even drive on. There are so many reasons to protect the Roadless Rule and be opposed to the rescinding of it – backcountry hunting access, wildlife habitat, clean drinking water, and nature as a whole. But have we considered that maybe, we wouldn’t even be able to use the new roads they’re proposing? Why would we be able to, when we can’t even properly use the ones that currently exist? There are 265,000 miles of roads that the U.S Forest Service alone maintains in the United States. There are 165,000 miles of road in the National Highway System. If you agree we should work on maintaining those 265,000 miles of roads first, do not rescind the roadless rule. Let's keep one part of our country roadless, where only feet and hearts can reach. Please. I oppose the proposal to rescind or alter the Roadless Rule, and I support Alternative 1, the No Action alternative.

I respectfully urge the US Forest Service to maintain the Roadless Area Conservation Rule by selecting Alternative 1: No Action. In 2001, As a citizen volunteer, I communicated with Montanans about their use of roadless areas and the potential benefits of a Roadless Rule to Montanans, to national forests in Montana and other large US forested areas. I worked with many others throughout our state. Along with the public participation in other states, a consensus was established that resulted in the Roadless Rule. Participation of the public at ground level was essential in establishing the Roadless Rule. Unfortunately, public participation, people communicating with each other and with the government at local levels is missing in this proposal. Due to its many benefits, people realize throughout the country realize that the Roadless Rule is even more valuable now than in 2001. Although one of the priorities of this proposal is building new roads in prevention of forest fires, the draft Environmental Impact Statement indicates that new roads will lead to significantly more wildfires, not fewer, and result in increased risk of fires near communities such as many rural communities near roadless in areas in Montana and other states. According to Montana’s Senator, Tim Sheehy states, in his Aug 29, 2026, guest column in the Bozeman Daily Chronicle, “The wildland-urban interface is the new front line.” Developing fire-hardened landscapes and investing in fire-safe infrastructure is the path forward. He also states we should centralize wildland-urban interface planning and suppression as a goal, focusing on areas that threaten population centers and prioitize life-saving action. Clearcutting forests to build new roads in roadless areas is the opposite of Senator Sheehy’s recommendations. Additionally, evidence shows that most wildfires are human caused and increased by drought, high wind, high temperatures, and low humidity. These factors are all on the rise. Besides increasing the risk of wildfires, wildfires cause sedimentation to increase which harms fisheries, spread weeds, and destroys wildlife habitat. New road construction would add to the already immense, costly backlog of UFS road maintenance projects that have been delayed for years. If the Roadless Rule were rescinded, about 6 million acres of wild national forest lands in Montana would be at risk commercial logging and road building. Nationwide that includes the risk for about 45 million backcountry acres. Backcountry roadless areas in Montana, including the Gallatin National Forest, Bridger-Teton National Forest, and Badger-Two Medicine are places where I walk, hike, cross-county ski and engage in birdwatching, wildlife watching, and other forms of quiet recreation. Roadless areas provide key connectivity areas and migration corridors for Montana’s iconic wildlife such as elk, mule deer, antelope, grizzly bears, moose and Canada lynx. Some of the most secure habitats for fish and wildlife exist in roadless areas. Roadbuilding and commercial development would lead to loss of habitat and increase the risk of human-caused mortality of wildlife. I oppose the Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule because rescinding the Roadless Rule would increase the risk of wildfire, harm wildlife and wildlife habitat, and harm the public’s ability to recreate, hunt, fish, and fully enjoy the multiple uses of roadless public lands. I urge the Forest Service to follow established science and the will of the people by retaining the Roadless Rule.

I urge the US Forest Service and the US Department of Agriculture to KEEP the 2001 Roadless Rule. For the first time in my life, I took a road trip across the entire lower 48 of the United States this last summer. We hiked and camped in many marvelous and priceless wilderness areas, such as the Absaroka-Beartooth Wilderness in Custer Gallatin National Forest (Montana). The ecosystems and landscapes protected by the Roadless Rule are absolutely irreplaceable. The beauty and vastness of these protected forests are what truly makes America great. We must protect them for future generations from large-scale logging, road construction, and other development that will industrialize our national forests. The Roadless Rule has protected irreplaceable roadless values while permitting fire suppression, fuels mitigation work, trail maintenance, and other forest management activities for the past 25 years. It is a fiscally responsible, environmentally sound, multiple-use management tool. I implore you NOT to rescind the Roadless Rule. Patrick Erben, Carrollton, Georgia

To the Department of Agriculture: I grew up in Montana, and have worked for the Forest service in multiple capacities as well as numerous years of recreating in Wild areas across the United States. For a person who has sought out roadless public land across different regions and in different seasons, I'd say the 2001 Rule is one of the clearest expressions of what the public land system is supposed to protect — and rescinding it would be a clear statement about what it isn't. I grew up exploring places like the Crazy Mountains as well as others nearby. My wife and I recently hiked to the blue lakes, where we were able to access an alpine area filled with unique wildflowers with no other person in sight. Places accessible only by foot, that are protected from destruction by bulldozers and tires Regarding the Crazy Mountain in the Gallatin National Forest, Montana: Alpine and Subalpine Climate Refugia — The area's high-elevation ecosystems—Rocky Mountain Alpine Turf, Alpine Dwarf-Shrubland, and Whitebark Pine/Subalpine Fir Woodland—occupy the summits and ridges of peaks exceeding 10,700 feet and represent climate refugia where species can persist as lower-elevation habitats warm. Whitebark pine, a federally threatened species and IUCN-listed endangered species, depends on these high-elevation zones where it grows in association with subalpine fir; the species is already declining across the West due to white pine blister rust and mountain pine beetle. Road construction at high elevations would remove the canopy structure that whitebark pine requires and would increase human access that spreads invasive pathogens, directly undermining recovery prospects for this species in one of its remaining strongholds. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. “Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2)” The Department's obligation under the APA is to provide reasoned explanation commensurate with the significance of the policy change; that obligation has not been met, and rescission should be denied. All the best, CommentID: RLC-20261006-E8VZJB

To whom it may concern, I object to the repeal of the USFS Roadless Rule, as implemented in 2001 and judicially reconfirmed in 2006 and 2009. It is an appropriate, balanced, and science-grounded rule that protects our greatest natural resources. USFS land is managed under a multiple-use mandate, with both recreation and extraction interests. A majority of land under USFS control is already accessible by roads and provides ample land and growth capacity for the timber industry. The areas protected under the Roadless Rule are one of this country's greatest successes of responsible stewardship. As a child of the Bozeman, MT area, I grew up recreating, exploring, and hunting in and about the Custer Gallatin National Forest. The relatively minimal (~$100s of millions) timber industry revenue is balanced by the anticipated short-term financial impacts to recreation, and is catastrophically outweighed by the long-term damage to some of the last remaining truly wild areas in the US (both the contiguous 48 and the broader country). The Roadless Rule additionally protects our forests from wildfires, the great majority of which are human-caused and which occur disproportionately near roads. The Roadless Rule incorporates reasonable exceptions for USFS and authorized contractors to perform preventative and responsive wildfire operations, whether in the form of limited timber harvest or emergency road construction. This directly contradicts some of the intended rationale behind the repeal. The Roadless Rule is overdue for science-based updates, but a full repeal is an irresponsible abdication of stewardship to the conservation portion of the USFS's mandate, and is unlikely to accomplish substantial long-term economic benefits. Thank you.

I am opposed to the recision of the rule. I have personally had loved experiences in the landscapes this rule protects and hoping to provide the same experiences for my children and grandchildren. I have hiked and camped in the Custer Gallatin National Forest in Montana, and camped and driven through the Caribou-Targhee National Forest on the Idaho-Wyoming border. They are beautiful. These places should not build roads as it would ruin the serene scenery; once a road is built the experience is gone forever.

I have lived next to the Gallatin National Forest for over a half century and witnessed the gradual yet consistent denigration of roads, trails, lakes and streams by the growing population of Bozeman. Invasive plants are pushing out native plant communities, large trees have literally been shot down on private property by reckless gun owners, trails are eroding sediments into near by streams by over use, litter is increasing and the noise of utility vehicles and motorcycles is constant. We need federal protection of our roadless areas to prevent this type of misuse from increasing population pressures. I have no problem with what is called "sacrificial landscapes" to satisfy the urge of motorists but roadless areas must stay roadless for future generations to enjoy the peace that nature provides as well as protect animal species under increasing pressures. States will cave in to special interests and money when it comes to conservation. The Federal government must control and maintain roadless areas. We must be protected from ourselves, unfortunately. The destruction I've seen is heartbreaking. PLEASE DO NOT RECIND THE ROADLESS RULE!!!

Re: Docket FS-2025-0001, Proposed Rescission of the 2001 Roadless Area Conservation Rule I strongly oppose rescinding the Roadless Area Conservation Rule and urge the Forest Service to adopt the No Action alternative and keep the rule in full. I am a painter of the plants, birds, and animals of America's wild public lands, and I work from direct observation in the places themselves. I have attached examples of that work. On the Little Cherry Creek Trail in the Gila National Forest in New Mexico, I found a painted redstart, a small jewel of a warbler and one of many birds I saw for the first time in that forest. In Montana's Custer Gallatin National Forest, my husband caught a native Yellowstone cutthroat trout in a backcountry stream, and I painted it. I have also painted fish he caught on a daylong horseback trip into the Bob Marshall Wilderness. Native trout like these survive only where headwater streams stay cold, clear, and connected. New roads and logging send sediment into exactly those streams. Wilderness areas like the Bob Marshall also depend on the roadless lands around them, which serve as buffers and corridors that wildlife and clean water cross freely. In 1993, while my husband fished, I painted a backcountry stream in Alaska's Tongass National Forest. We hiked in to reach it, as we did to many places there. The Tongass has had its roadless protections removed and restored before, and the public spoke clearly then in favor of keeping them. On Mt. Blue Sky in Colorado, I drew a bristlecone pine more than 1,500 years old, which I call "Old Man of the Mountain." I have also stood before a 3,000-year-old bristlecone in Great Basin National Park and touched it. That tree has lived through the rise and fall of civilizations, through humanity's greatest achievements and greatest sorrows. It survives because the land around it has been protected. Standing in the presence of something that ancient is awe-inspiring, but it is also a heavy responsibility. These trees, fish, and birds will outlast every one of us only if we decide to let them. The Roadless Rule is that decision, already made, and it has worked for twenty-five years. The proposal argues that rescission will give local managers flexibility and improve forest health and wildfire response. The existing rule already allows fuel reduction and other necessary work, especially near communities. New roads into remote backcountry add human-caused fire ignitions, fragment habitat, and degrade the streams that supply clean drinking water and cold-water fisheries. Roads also cost money to build and maintain, and the Forest Service already has a large backlog of road maintenance it cannot afford. I ask that the final EIS explain how adding roads to remote areas reduces wildfire risk better than focusing fuel work near homes and towns. The draft EIS must also fully account for the permanent nature of these losses. A road can be built in a season and an old forest cut in a day, but what they destroy took centuries or millennia to grow. No later policy can restore it on any timescale that matters to us or to our grandchildren. These lands belong to all Americans, including the hunters, anglers, hikers, and artists who go to them to escape the noise of everyday life. I am one citizen, but these lands are mine as much as anyone's. Keep the Roadless Rule. Attachments: Field journal, May 5–7, 2023, including painted redstart and red-faced warbler, Little Cherry Creek Trail, Gila National Forest, NM Native Yellowstone cutthroat trout, Custer Gallatin National Forest, MT "Old Man of the Mountain," bristlecone pine, 1,500+ years, Mt. Blue Sky, CO Watercolor study, backcountry stream, Tongass National Forest, Southeast Alaska (likely Wrangell Island), 1993 Kelly Leahy Radding Connecticut