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I am a former USDA Forest Service employee, a backpacker, hiker, and frequent user of public lands, and I am vehemently opposed to rescinding the 2001 Roadless Rule. A USDA FS study by Sean Healy, "Long-term forest health implications of roadlessness" in 2020 from the Rocky Mountain Research Station found that increasing roads does not increase fire management, and spreads invasive plant species. The taking away of the Roadless Rule will also encroach on Native American sovereignty and access to their ancestral lands, including sacred sites, and have countless negative reverberations. It will also result in long, costly lawsuits - and I would know, as I was an employee on the most litigated National Forest in the United States of America, the Helena National Forest. As it is, more road building would mean more road maintenance, and per the USDA FS 2026 Q2 Fiscal Report, there is already over $6 billion dollars of deferred maintenance on our roads alone - and a backlog of over $11.4 billion dollars of deferred maintenance in total. The Center for Biological Diversity released a report in August 2026 that notes that rescinding the Roadless Rule would put almost 7.5 million acres of endangered animal's habitat at risk, alongside 1,500 miles of creeks, streams, and rivers, at risk for contamination by sediment and other pollutants. National Forest water sources provide drinking water for millions of Americans. I love being a Montanan, hiking on National Forest lands in one of the most intact wilderness states in the lower 48, sharing my world with wolverines, grizzly bears, wolves, and countless other species, flora and fauna alike, who would be threatened and stressed by road incursion into their habitat. Americans do not have much in terms of patrimony to be proud of. We do not have affordable healthcare. We do not have affordable college, or childcare, or family leave, and our federal minimum wage is still $7.25. In Montana, we have had to fight for so long to regain clean water, clean soil, and a healthy environment after decades of intensive resource extraction from mining, timber harvesting, and other industries gutted our land and water. What we do have is our public lands, and our access to them for not just this time but for all time - and not for greed, for enriching private corporations, but for preservation, public use, and for the flora and fauna we are so lucky to live amongst.

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 writing concerning rescission of Special Areas roadless rule conservation at 91FR 53287. Having been born and raised in Marysville and owner of a home at 6950 Lost Horse Creek Road I have spent the majority of my 78 years recreating in the Helena National Forest including the the proposed roadless area study. I see no rational reason for this area to be roadless for several reasons. It is surrounded by public and private land and is utilized primarily by sportsmen and the occasional hiker. I feel strongly that the time and money would be better spent improving existing roads such as the Ophir Creek road, Marsh Creek road and Mullen Pass road all of which are used by the public much more. Sincerely, Rick O’Connell 496-459-7837 oakes1948@gmail.com

We are commenting on the 2001 Roadless Area Conservation Rule reference RIN 0596-AD66. We are adamant that we are not in favor of reversing this ruling and opening up the USA to developing roads for logging, mining extraction permits or mine development. We are local land owners who live adjacent to the Helena National Forest and the Lewis and Clark National Forest. We hunt in the national forest, recreate there as well. We depend on springs to irrigate our pastures that support cattle grazing on our land. There is value of having intact backcountry recreations. The two mentioned forest above support wildlife habitat for grizzly bears who use these forest as a corridor to the Yellowstone area. Canada lynx use these forests as a breeding ground to rebuild their population in Northwest Montana. The Continental Divide National Scenic Trail goes through these forests. Roadless areas protect wildlife habitat, biodiversity and migration corridors, keep invasive species at bay, prevent pollution and soil erosion into waterways. The roadless rule is an ecological boon to the Western United States landscapes where most of the affected areas are located. A 2020 Forest Service study concluded, after nearly 20 years of monitoring data, that more roads do NOT lead to a better forest health through increased fire-management studies. The National Environmental Policy Act requires government to conduct environmental impact assessments on proposed rule changes, a process that can take years. The Trump Administration is fast-tracking that timeline for repealing the roadless ruling and opening up mine extraction permits, logging and again, mines. Blue Copper Project is currently asking for a permit to extract metals from the USFS in our backyard. We are located 1/4 mile from the project's boundary. This is where we live and grow hay for cattle. The backlog of deferred maintenance has grown rapidly according to the draft environmental impact statement the cost of unaddressed maintenance needed just for roads and bridges that can carry passenger vehicles reached US $6.9 billion in 2024. Where is the tax burden going to fall when more roads are built? We must slow down and protect 45 million acres NOW so future generations can enjoy the same freedom to explore wild public lands that we do today. Consider our comments and those of others who are in favor of keeping our Country's roadless areas intact.

As a son of a UCLA graduate I have enjoyed our family trips to far off wilderness places in the Northwest including Lake Tahoe Basin, the Lassen National Forest, Sequoia National Forest in CA along with Helena National Forest in Montana, to name just a few. These are vital places where we go to enjoy hiking, birdwatching, and outdoor activities in a rich, thriving ecosystem. I am very concerned if the Roadless Rule is repealed, construction and road development will deplete these natural resources along with access to safe drinking water that more than 25 million Americans rely on every day. Building more roadways through dense forested regions that are road free will not achieve the stated goals the USDA is claiming in their August rule change - 36 CFR Part 294 | RIN 0596-AD66. From 1992 to 2024, across 8 US Forest Service regions, wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares). The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 hectares). Source: 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 Roadless areas protect drinking water supplies millions of Americans depend on. Inventoried Roadless Areas protect roughly 131,000 km of rivers nationwide and are the strongest protection mechanism for over 100,000 km of river (Olden et al., 2026). An estimated 25 million Americans get drinking water from these watersheds, with five states (Arizona, California, Colorado, Georgia, North Carolina) each having over a million water customers (Olden et al., 2026). USDA's Draft EIS (2026) notes nearly 5 million people in the Pacific Southwest Region draw drinking water directly from watersheds containing roadless areas, plus over 1 million more in the Intermountain Region and 4 million more across the Northern Rockies, Rocky Mountain, and Intermountain Regions combined. Repealing the Rule risks these sources via added sedimentation and erosion from roads and logging. Protecting forested watersheds also cuts costs: seven U.S. cities avoided hundreds of millions in annual treatment costs this way, and each 10% rise in forest cover cuts treatment/chemical costs by about 20% (Olden et al., 2026). Roadless areas are also essential habitat for threatened and endangered species. The Forest Service's Draft EIS found a "may affect, likely to adversely affect" determination for 327 ESA-listed species and 71 critical habitats under the repeal (USDA Forest Service, 2026). Roadless Areas hold over 220 threatened/endangered species—about 25% of listed/proposed animal species and 13% of listed plant species nationwide (Loucks et al., 2003). The six grizzly bear recovery zones in the northern Rockies include roughly 15,300 sq km of Inventoried Roadless Areas, with nearly 24,750 sq km of contiguous IRAs around the Salmon-Selway Zone alone (Loucks et al., 2003). Wolves need road densities below about 0.5 km/sq km to persist, yet few Middle Atlantic Coastal Forest areas meet that threshold (Heilman et al., 2002). Rescinding the Rule would open this habitat to new roads, undermining recovery of these species. In summary, the roadless rule protects critical watersheds that +25 million Americans rely on for clean drinking water. Furthermore, overturning the Roadless Rule will not help mitigate forest fires though by means of "land management planning," however, scientific studies indicate most fires started in forests are from human beings and occur within 50m of roadways. Source: 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 Thank you for your time and considering my feedback and the data on key considerations regarding the future of the Roadless Area Conservation Rule. Heilman, G. E., Jr., Strittholt, J. R., Slosser, N. C., & DellaSala, D. A. (2002). Forest fragmentation of the conterminous United States: Assessing forest intactness through road density and spatial characteristics. BioScience, 52(5), 411–422. https://academic.oup.com/bioscience/article/52/5/411/236110 Olden, J. D., Postel, S. L., Dombeck, M. P., Kesting, H., Freeman, P., & Comte, L. (2026). Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water, 5(7), Article e0000538. https://doi.org/10.1371/journal.pwat.0000538 U.S. Department of Agriculture, Forest Service. (2026, August 19). Draft environmental impact statement—2001 Roadless Rule rescission (Vol. I). Docket No. FS-2025-0001. Loucks, C., Brown, N., Loucks, A., & Cesareo, K. (2003). USDA Forest Service roadless areas: Potential biodiversity conservation reserves. Conservation Ecology, 7(2), Article 5. http://www.consecol.org/vol7/iss2/art5

Dear Secretary Rollins, I strongly oppose the Proposed Rule rescinding the 2001 Roadless Rule. Roadless portions of the National Forest provide protection to watersheds, fish and wildlife habitat, and provide recreational opportunities not found in developed areas. I spent many days backpacking and fishing in roadless areas of the Custer and Gallation National Forest as a young man and I still fish and hunt in roadless areas of the Helena National Forest. These are wonderful experiences i can not get in developed forests, no matter how much money I spend. Rolling back the Roadless Rule will open irreplaceable Montana landscapes up to large-scale logging, road construction, and other development that will industrialize our national forests. Once these areas are develped they will never be the same again. 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 that needs to be continued. Please adopt the No Action alternative for the Final Rule. Sincerely, Mr. Rudy Verzuh Montana