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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