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I am a long term (30 year) resident of Kanab, in Kane County, Utah, on the doorstep of the magnificent Kaibab Plateau, part of the North Kaibab National Forest. My family has grown up hiking, camping and exploring this forest, and many other United States Forest Service (USFS) lands in Utah. My husband and I remain avid hikers in this area, as well as regularly traveling to other states to hike and camp on USFS lands- Montana, Wyoming, Idaho, Colorado, Nevada, Arizona, California, New Mexico, North Dakota, South Dakota, Oregon, Washington, Iowa, Tennessee, Wisconsin and Illinois. I deeply value the wilderness qualities, scientific enrichment, recreation, and quiet solitude that public forests have provided me for the last forty years. What happens to these lands, and especially the forests, is very important to me. Our local North Kaibab Forest already has plentiful roads and is busy with recreation and harvesting activity. Yet, one can still find solitude and quiet. It will deeply and negatively affect my experience on this local forest if more roads are built, increasing human and commercial/industrial impacts and noise pollution. The U.S. Department of Agriculture (USDA) has proposed repealing the 2001 Roadless Rule (Rule). This Rule has been in place with bipartisan support for 25 years and has protected roughly 4 million acres of old-growth and undeveloped USFS lands in Utah (and 45 million acres nationwide) from road building and commercial logging. I strongly oppose this proposed repeal, as it will irreversible damage these forest lands- roads bring activity. With roads, whole forest areas will be inevitably be opened to more industrial development, extraction, and privatization. New roads make commercial logging, mining, drilling, and other damaging development easier. These activities cause the fragmenting of habitat, erosion of soils, degradation of streams, the spreading of invasive species and light and sound disruption. New roads increase human disturbance in places that were largely whole. Once the forests are developed in this way, they are forever changed. Once you cut down stands of majestic trees, the ecosystem suffers. Human disturbance degrades the silence. All over the country, Roadless forests safeguard river headwaters that provide drinking water for millions of people and preserve wildlife habitat for hundreds of species of plants and animals. Whole, intact forest ecosystems support climate resilience. Many roadless forests are critical to the livelihood and culture of local native tribes, as the Kaibab Plateau is for the Kaibab Paiute People. There are already more than enough roads on the North Kaibab Forest, and in most national forests that I have visited. There are several hundred thousand miles of roads nationwide. There is a multibillion-dollar maintenance backlog for these existing roads- it would be wise and responsible to fix these roads before making new ones. The Roadless Rule has never closed roads or prevented people from reaching trailheads- it has benefitted outdoor recreation. Roadless forest areas are open for hiking, camping, hunting, fishing, and other recreation. The Rule also allows for fire suppression, fuels work and emergency road building for wildland firefighting. And yet the Rule strikes a balance that protects critical wildlife habitat, water, plant life, soils, solitude and cultural resources, values that visitors seek and enjoy. The Rule has protected the forests. It should not be repealed. Thank you for consideration of my comments.

I am opposed to changes to the roadless rule. It is a significant measure that has been effective in preserving and managing natural resources, hiking, fishing and hunting opportunities that the public enjoys and support. I have been a visitor to national forest lands in Colorado (Uncompahgre NF, Rio Grande NF, White River NF), Utah (Dixie NF, Fishlake NF), California (Sierra NF, San Gabriel NF, others), Arizona (Coconino NF, Kaibab NF), others. I support the roadless rule and I don’t support eliminating it. Yes, the President’s donors may be trying to benefit from removing the rule, but a majority of the public supports preserving it. Utah politicians like Lee may claim no one supports measures like the roadless rule, but he is undoubtedly pandering to outside interests.

I absolutely oppose recending the 2001 roadless rule. In other words, i support Alternative 1 (no action) I live in Arizona and use the national forest for recreation. This includes the Coconino, Coronado, Apache Sitgreaves and Kaibab National Forest. These lands provide an immense amount of recreational value and the current roadless areas are a big help when preserving clean water, providing wildlife habitat, and helping prevent forest fires (since most human caused fires are associated with roads). Not to mention the finacial/maintenance backlog of maintaining additional roads. These roadless areas provide immense economic value due to the economy created by recreational activies. thank you, John Malusa 520-404-0753 Tucson Arizona

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The wildness, quiet, and wildlife in these forests are a major reason I go there. I hike and paddle across the Tonto, Coconino, and both units of the Kaibab National Forest. I run the Salt River, the Verde, the Gila, and the Colorado. I photograph landscapes, the diversity of plants, and wildlife you can find nowhere else. These undeveloped areas define what those places are. More roads would change the very qualities that make them worth going to. I am filing this comment to oppose rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. I also volunteer regularly with the National Forest Service. I have seen firsthand how important these areas are. When fire moves through roadless country, regeneration comes back quicker and the damage is not as severe. That observation is consistent with what peer-reviewed science shows. It is also consistent with what the agency's own data show, which makes the reasoning behind this proposal hard to follow. The agency's effects analysis quantifies human-caused ignition density at 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, drawing on a full decade of data, and states directly that "human-caused ignitions increase in abundance with proximity to roads" (DEIS Table 21, 2014-2024). The DEIS concedes that road access could increase the number and frequency of wildfires. Yet the proposal presses forward on the premise that opening these areas reduces fire risk. The agency must quantify the expected increase in human-caused ignitions that would follow from new road access, weigh that increase against the claimed reduction in wildfire hazard, and explain the discrepancy in its final analysis. The national forest road system already exceeds 300,000 miles. The Forest Service has documented chronic underfunding of road maintenance. Explain to me how it is fiscally responsible to neglect existing road infrastructure while proposing to open what remains of our roadless forests. That question becomes sharper when the agency's own document quantifies the soil cost: the DEIS states that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That figure appears in the document. No projection of sediment delivery to downstream water intakes follows it. The agency should quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of affected roadless areas before this rule moves further. The small-business certification in the supporting regulatory flexibility analysis reaches its no-impact conclusion by distributing the loss across every small firm in the sector nationally. The agency's own Cost Benefit Analysis tells a different story: "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." The outfitters and guides who hold permits and run trips in the rivers and forests I have described are not a national average. They are specific businesses in specific places, and some of them will lose these receipts. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. I paddle these rivers and walk these forests because they remain largely intact. That relationship is exactly the kind of interest the proposal itself invites comment on. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under established administrative law, an agency reversing course must grapple with the reliance interests its prior policy created. This comment is one. The agency should identify and weigh the reliance interests described in the comments it receives, including this one, before a final rule issues. Taxpayer dollars should go toward repairing existing roads, improving drainage, and preventing stream damage. The places I photograph, paddle, and walk through have value precisely because they have been left alone. Nothing in this proposal accounts for that adequately. Sincerely, Jim Dublinski Scottsdale, AZ

I live in Scottsdale, Arizona. I urge the Department to withdraw this proposal, adopt the No Action alternative, and retain 36 CFR 294 Subpart B in full. I spend a large part of my life in places this rule protects. I'm an off-trail backpacker who has spent more than a month below the Grand Canyon's rim, often starting from the Kaibab National Forest. I'm also a mountain biker, bikepacker, and former professional bike mechanic involved in Arizona cycling events. To me and to the communities around these lands, their value comes from the absence of roads. 1. The proposal's own analysis does not support its stated need. The Summary of Potential Impacts says management opportunities "would be modest and localized." It also says broad timber harvest gains are unlikely because of budgets, operability, and markets. A modest, uncertain benefit does not justify removing a protection that has worked for 25 years. The existing rule already allows small-diameter timber cutting to reduce the risk of uncharacteristic wildfire (§294.13(b)(1)). It also allows roads when there is an imminent threat of fire or flood (§294.12(b)(1)). The proposal's complaint is that these exceptions have been applied in a "limited and inconsistent" way. That is an administrative problem the agency can fix with guidance, not a reason to repeal the rule. 2. Roads add fire risk, and the agency cannot maintain the roads it already has. The proposal acknowledges that greater access can increase human-caused ignitions. It also acknowledges a $6.9 billion deferred maintenance backlog for roads and bridges. Adding miles to an unfunded road system degrades watersheds and sends sediment into streams and drinking water sources, which the agency itself names as conservation priorities. 3. The economics favor keeping the rule. The analysis estimates recreationists could lose about $6.1 million each year. The offsetting timber revenue of $5.2–11.4 million is a figure the agency itself says is unlikely to be fully realized. Recreation value recurs every year, while harvest revenue is speculative. The proposal also concedes tradeoffs with "quiet, remote and self-reliant recreation," which is scarce and cannot be replaced. Once a roadless area is roaded, it cannot be restored on any practical timeline. 4. Forest plans are not an equivalent safeguard. The proposal says rescission does not require any plan amendments. It also says local officials could later amend or revise plans to allow more roads and harvest, and that those changes fall outside this analysis. So the real impacts of rescission have not been analyzed. Protection for tens of millions of acres would come to depend on separate decisions, forest by forest, with no national floor. A consistent national standard is what makes these protections durable. 5. The public and Tribes have already weighed in. The overwhelming majority of comments on the notice of intent opposed rescission. The proposal itself reports that most consulted Tribal governments oppose it, citing sacred sites, subsistence resources, and water quality. Going ahead despite that record undermines the legitimacy of this process. 6. Reliance interests. The Department asked about reliance interests. For a quarter century, outfitters, guides, event organizers, and residents have planned their livelihoods and recreation around intact backcountry. [Optional: add a specific place you use or an event you support.] I ask the Department to select the No Action alternative and keep the 2001 Roadless Rule in place. Sincerely, Gerrit

To the Department of Agriculture and the Forest Service: As an outdoor enthusiast, I am entering the record to observe that the 2001 Roadless Area Conservation Rule represents a considered administrative judgment that the public interest in roadless national forest — ecological, recreational, and watershed-related — outweighs the interests served by road-building authorization, and that the Department's proposed rescission has not offered a sufficiently developed basis for overturning that judgment. Regarding the Coconino Rim in the Kaibab National Forest, Arizona: Road building and vegetation management reshape fire regimes by changing ignition sources, fuel loads, and landscape-scale fire behavior. Most ignitions near roads are human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Wimberly, 2012 (https://doi.org/10.1016/j.apgeog.2011.09.004); Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Rescinding the Roadless Rule would open the Coconino Rim, Kaibab National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. “Although roadless areas tend to be cooler, moister, and higher elevation, they experienced greater fire extent than roaded areas over the past three decades. Critically, however, there was no significant difference in fire severity after accounting for biophysical differences. The authors suggest the greater extent of fire in roadless areas "may confer resilience to these landscapes in the face of climate change." — Johnston et al., 2021 (https://doi.org/10.1088/1748-9326/ac13ee)” Rescinding the roadless rule will create greater fire risk Keep the Roadless Rule. Don't rescind. Yours truly, CommentID: RLC-20261005-VOX7I2

I am an Arizonan and I recreate on public land almost daily. Public lands are central to the lifestyle and traditions that citizens like myself deeply value as Americans. I recreate on the Coconino NF, Kaibab NF, Tonto NF, Coronado NF, Prescott NF and the Apache Sitgreaves NF. I am an angler, hunter, backpacker, archer, recreationist, and roadless areas are central to my way of life. It is imperative that backcountry areas are conserved for my children's generation and for generations to come. As a scientist, I believe that the rationale behind rescinding the roadless rule is built on faulty logic and poor presumptions instead of evidence. The rescission of the Roadless Rule is dangerous and not backed by solid science. The benefits of the Roadless Rule as they are written protect wildlife, watersheds, ensure proper wildfire management, protect clean water while providing the flexibility land managers need. The Roadless Rule does not limit active forest management. Land managers are able to treat high fuels areas while preventing the construction of permanent roads. The data clearly show that wildfire risk increases in areas with roads. I support scientifically informed forest management from local experts who understand the impacts of recreation and forest health. Eliminating the Roadless Rule is dangerous and puts our forests, citizens, wildlife and firefighters at greater risk. In Arizona, wildfire ignitions are nearly seven times more likely near roads according to a report from The Wilderness Society. Introducing new road systems will increase fire frequency and put our fire fighters in harms way. The impact of rescinding the Roadless Rule will affect 45 million acres of land while federal land management agencies remain underfunded and understaffed. This proposal is being made while the Forest Service is experiencing a major reorganization including the elimination of regional offices, relocation of staff and a reduction in force. How does removing long-standing protections amid a major agency restructuring benefit the American people and the lands we all share? It does not. Thank you for the opportunity to comment on the Roadless Rule.

Dear Secretary and Chief: I am a college student studying forestry, I use these public lands on a monthly basis and once I graduate, l plan to work to protect them for future generations. As a conservationist, have observed that the administrative architecture of the 2001 Rule its national scope, its inventory based approach, its exemptions framework reflects deliberate design choices made to withstand both legal challenge and political pressure The Department's proposal dismantles that architecture without replacing it. 44.5 million acres of roadless forests protected by the 2001 Roadless Rule (excluding Idaho and Colorado, under their own state rules) I stated before that I camp in these roadless areas, these areas are important to me and the local wildlife who depend on these habitats. Mexican Spotted Owl (Strix occidentalis lucida) is an endangered species and relies on these forests from these roadless rules. Removing these rules could further in danger or set this species to be extinct. "Many native forest plant and animal species require undisturbed interior forest habitats to persist and do not fare as well near stand edges adjacent to disturbances. Disturbance edges were characterized as having higher soil moisture content, higher soil temperature, and a thinner organic matter layer compared to the forest interior (> 10 m). The interior habitat indicator values show that less than 30% of the Cold Lake area is currently classified as undisturbed due to over 6000 km of linear disturbances including roads." — Springer Nature / Plant Ecology, 2024 Regarding the Coconino Rim in the Kaibab National Forest, Arizona which would be affected by this rule: Kaibab National Forest's Coconino Rim IRA contains 50.3% coverage (~3,632 acres) of Colorado Plateau Pinyon-Juniper Woodland (Colorado Plateau Pinyon-Juniper Woodland) (GNR), which NatureServe independently identifies as habitat for Pinyon Jay (Gymnorhinus cyanocephalus, G3). The species is separately documented present in the area. Road construction degrades this ecosystem and the imperiled species that depends on it. Pinyon Jay (Gymnorhinus cyanocephalus, G3) depends on the structural integrity of Colorado Plateau Pinyon-Juniper Woodland (Colorado Plateau Pinyon-Juniper Woodland) in Coconino Rim for the specific life-history requirements NatureServe's ecological association identifies. Road construction disrupts canopy closure, soil structure, and moisture regimes — the ecosystem attributes that make this habitat functional for this species. I’m going to college to join the first service when I get older and graduate. When I think of the forest service, I think of people who want to protect our lands for future generations to come and who enjoy taking care of our planet. I am deeply ashamed that the forest service would back this proposal, knowing the detrimental effects that could and will happen. We’re supposed to be here to protect nature who can’t speak up for themselves, we’re supposed to protect nature from greedy corporations that want to exploit our land more than it can give. "When the last tree is cut down, the last fish eaten, and the last stream poisoned, you will realize that you cannot eat money." This quote is a Cree Native American prophecy and it still holds true today. Please remember why you joined the forest service, if we don’t protect our lands now we won’t have them for future generations to come. The wildlife that needs these habitats won’t have them anymore. We forget that we’re a part of the Earth too. We’re also animals and we rely on the Earth just as much as they do. Yours truly, Sydney Dillon CommentID: RLC-20260930-MI8NIK

As a firefighter, sportsman, and public lands owner in Nevada and Michigan, with respect I urge the rejection of this proposed roadless area rule. This rule would harm wildlife habitat and water quality in places my family and I use and care about like the Humboldt-Toiyabe NF, Coronado NF, Kaibab NF, Coconino NF, Inyo NF, Modoc NF, Umatilla NF, Huron-Manistee NF, Ottawa NF and Hiawatha NF and others. It will also likely increase risk of human-caused wildfires, most of which start near roads. This unwise, politically-motivated rule fails the broad public interest for conservation of US forests, watersheds and rural economies. Thank you, Daniel R Patterson, Indian River MI / Boulder City NV

To Whom It May Concern, I strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. I am writing to demand that the U.S. Department of Agriculture and the Forest Service maintain the nationwide protections currently shielding our roadless backcountry areas from industrial exploitation. Over my life, I have had the unique privilege to visit, hike, and deeply enjoy these protected wild areas. I want that exact same opportunity to exist for future generations, but the structural damage being pushed by this administration will create irreversible environmental harms that can never be undone. As someone with a personal stake in the future of northern Arizona, I am submitting this comment to protect the fragile ecosystems surrounding Grand Canyon National Park and the adjacent Kaibab National Forest. The recent compounding tragedies on the North Rim of the Grand Canyon are a stark warning of what happens when we fail to prioritize landscape-scale conservation and watershed protection. In July 2025, the catastrophic Dragon Bravo Fire charred nearly 150,000 acres, destroying the historic Grand Canyon Lodge and leaving a massive, highly vulnerable burn scar across our public lands. This environmental trauma directly precipitated the devastating flash floods in Bright Angel Canyon on August 29. The rapid runoff from the burn scar triggered an influx of mud, rockfalls, and debris that destroyed footbridges, ruptured infrastructure, and tragically claimed human lives - and countless creatures who live in these areas. Despite explicit internal warnings from the park's own trail supervisor—who strongly urged that the North Kaibab Trail remain closed for the 2026 season due to elevated hydrologic risks and unstable trail integrity—the National Park Service and Department of the Interior chose to fully reopen the trail in May. Reopening a primary corridor trail beneath a highly volatile burn scar was a severe oversight in risk management. The agencies should have prioritized structural stabilization and climate-resilient engineering over rushing to clear crowds. Allowing industrial road building and logging under the guise of "flexibility" will only amplify these systemic vulnerabilities. The U.S. Forest Service’s own Draft Environmental Impact Statement (DEIS) reveals that repealing the Roadless Rule actually increases the risk of wildfire starts due to increased human activity and heavy equipment access. Industrial logging roads do not stop modern megafires; they invite more points of failure. Furthermore, building roads and cutting timber strips away the vegetative ground cover that slows down torrential monsoonal rains. As seen in Bright Angel Canyon, denuded landscapes cause immediate, lethal debris flows. Strip-mining the roadless protections from the 1.2 million acres currently protected in Arizona will inevitably lead to severe soil erosion into vital municipal and ecological streams. Stripping protections from the Kaibab National Forest also puts the broader Grand Canyon region at immediate risk for expanded commercial extraction, including uranium mining and commercial timber harvesting. Roadless areas serve as a vital buffer zone for wildlife corridors and hikers alike. The federal government must focus its limited funding and personnel on climate-resilient infrastructure and emergency systems for existing trails, rather than opening untouched backcountry lands to commercial exploitation. The shortsighted policy changes driven by the current administration risk permanently breaking the ecological trust meant for our children. These are public lands that should not be for sale to the highest bidder!!! For these reasons, I urge the agency to select the No Action Alternative and retain the 2001 Roadless Rule in its entirety. Sincerely, Kimberly Carpenter - Hiker, Nature Lover, Tax Payer! Phoenix, AZ 85044

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I currently live on the doorstep of Appalachia but grew up in the equally beautiful American Southwest. As someone who loves the desert, its varied and vibrant ecosystems and wildlife, I am concerned about opening up these pristine wildernesses to mining. The Kaibab National Forest in AZ is home to the Apache trout, and the Gila National Forest in NM is home to the threatened Gila trout. Both national forests and their waterways would be heavily impacted by rescinding the Roadless Rule. I spent summers as a kid fishing and camping in the Prescott National Forest, Tonto National Forest, and the Apache-Sitgreaves National Forest. Many formative and wonderful memories were made under those ponderosa pines, crossing paths with elk, catching trout, and identifying the coolest-looking mushroom. In Appalachia, a region that has been the victim of an extraction economy for generations, the last thing we need is for roads to cut through our precious few remaining remote pockets of wilderness for logging and mining interests to take hold. Aside from increasing vehicle collisions with wildlife, encroaching roads in these landscapes would have a lasting negative effect on wildlife. And where roads go in, logging and mining follow. It is a repeatable cycle that we have watched play out for decades as our last wild spaces are slowly eaten away for corporate profit. Habitat loss due to deforestation, logging, and mining has led to the extinction of species in America that were robbed from all following generations. I will do my part to protect public lands to keep even just one species from the wretched fate of the Ivory-billed woodpecker and many others. As a reminder, public land belongs to the American People, who overwhelmingly support protecting the Roadless Rule fully and keeping public lands in public hands. The privatization of these lands is anathema to the American ethos and what is largely considered the greatest American invention, the establishment of National Parks and National Forests across the country. Saved, preserved, and restored for the American people forever. For the reasons listed above and a multitude more, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake that would have a permanent and lasting effect on the beautiful biodiversity of MY public lands.

To Whom It May Concern, I strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. I am writing to demand that the U.S. Department of Agriculture and the Forest Service maintain the nationwide protections currently shielding our roadless backcountry areas from industrial exploitation. Over my life, I have had the unique privilege to visit, hike, and deeply enjoy these protected wild areas. I want that exact same opportunity to exist for future generations, but the structural damage being pushed by this administration will create irreversible environmental harms that can never be undone. As someone with a personal stake in the future of northern Arizona, I am submitting this comment to protect the fragile ecosystems surrounding Grand Canyon National Park and the adjacent Kaibab National Forest. The recent compounding tragedies on the North Rim of the Grand Canyon are a stark warning of what happens when we fail to prioritize landscape-scale conservation and watershed protection. In July 2025, the catastrophic Dragon Bravo Fire charred nearly 150,000 acres, destroying the historic Grand Canyon Lodge and leaving a massive, highly vulnerable burn scar across our public lands. This environmental trauma directly precipitated the devastating flash floods in Bright Angel Canyon on August 29. The rapid runoff from the burn scar triggered an influx of mud, rockfalls, and debris that destroyed footbridges, ruptured infrastructure, and tragically claimed human lives. Despite explicit internal warnings from the park's own trail supervisor—who strongly urged that the North Kaibab Trail remain closed for the 2026 season due to elevated hydrologic risks and unstable trail integrity—the National Park Service and Department of the Interior chose to fully reopen the trail in May. Reopening a primary corridor trail beneath a highly volatile burn scar was a severe oversight in risk management. The agencies should have prioritized structural stabilization and climate-resilient engineering over rushing to clear crowds. Allowing industrial road building and logging under the guise of "flexibility" will only amplify these systemic vulnerabilities. The U.S. Forest Service’s own Draft Environmental Impact Statement (DEIS) reveals that repealing the Roadless Rule actually increases the risk of wildfire starts due to increased human activity and heavy equipment access. Industrial logging roads do not stop modern megafires; they invite more points of failure. Furthermore, building roads and cutting timber strips away the vegetative ground cover that slows down torrential monsoonal rains. As seen in Bright Angel Canyon, denuded landscapes cause immediate, lethal debris flows. Strip-mining the roadless protections from the 1.2 million acres currently protected in Arizona will inevitably lead to severe soil erosion into vital municipal and ecological streams. Stripping protections from the Kaibab National Forest also puts the broader Grand Canyon region at immediate risk for expanded commercial extraction, including uranium mining and commercial timber harvesting. Roadless areas serve as a vital buffer zone for wildlife corridors and hikers alike. The federal government must focus its limited funding and personnel on climate-resilient infrastructure and emergency systems for existing trails, rather than opening untouched backcountry lands to commercial exploitation. The shortsighted policy changes driven by the current administration risk permanently breaking the ecological trust meant for our children. For these reasons, I urge the agency to select the No Action Alternative and retain the 2001 Roadless Rule in its entirety. Sincerely James Jackson Sonora, CA, 95370

I oppose the proposal to partially or fully rescind the Roadless Area Conservation Rule. I live in Flagstaff, Arizona, within two miles of Coconino National Forest. Coconino National Forest is home to multiple roadless areas, including, but not limited to, Padre Canyon (9431 acres), Walker Mountain (6382 acres), East Clear Creek (1613 acres). I am also near Kaibab National Forest, which is home to Coconino Rim (7213 acres) as well as many other roadless areas in Northern Arizona. These lands are incredibly important to me as someone who hikes, runs, bikes, and backpacks in these areas. The majority of my time is spent in outdoor spaces, I spend many hours per week on National Forest lands. If the Roadless Area Conservation Rule were to be fully or patially rescinded, I would have fewer natural places to hike, bike, or run with my family. In addition to my personal concerns of losing our country's natural lands, the resciding of the Roadless Area Conservation Rule poses both ecological risks but also safety risks to humans. Many roads in National Forests are unmaintained, and thus we have some information on what happens when we make roads and leave them there without maintenance. I have been traveling through National Forests since 2018 and have seen plenty of unmaintained roads. They are often difficult to drive on, so much so that many indivudals get stuck attempting to drive on them. Unmaintained roads also tend to errode more. A good example of this is a road near me- Elden Lookout Road- which has may switchbakcks along the way and is a mostly gravel road. It's clear that since Elden Lookout Road was built in the early 1900s, that it has required maintenance to prevent errosion. Even so, this road is clearly continuing to errode and will likely require maintenance in the future. Allowing more roads in areas that don't have them is creating more risk that is unnecessary and does not help the American people. As stated in 'Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads' (2026, Aplet et al.) "roads also are known to increase ignition frequency." Creating roads is likely to increase the number of fires we have in these currently roadless areas, particularly when it comes to human-caused fires. The same study also states "Across the National Forest System and in every region examined, the density of wildfire ignitions within 50 m of a road is higher than in wilderness, Inventoried Roadless Areas, or other national forest lands, often by quite a bit (2026, Aplet et al.). Additionally, the US Forest Service's Draft of Environmental Impact Statement from August 2026 states that fully rescinding the Roadless Area Conservation Rule would adversely affect 327 threatened or endangered species and 71 designated critical habitats needed for those species (Page 25). According to page 24 of the same report, a result of rescinding this rule may also be "reducing forest soil productivity and water quality." In the event that timber harvesting and road construction occur, the report states that "soil, water, and air resources are loss of vegetation, soil erosion and compaction, loss of soil productivity, increased potential for landslides, reduced transpiration (use of water by plants), increased water runoff, reduced water quality, and periodically reduced air quality" are potential consequences (Page 24). For the many reasons above, fully or partially rescinding the Roadless Rule (under Alternatives 2 and 3 of the US Forest Service's Draft of Environmental Impact Statement from August 2026) would be a terrible and irreversible mistake. I wholeheartedly oppose the proposal to rescind or alter the Roadless Rule. I support the Alternative 1 (the No Action alternative) stated in the US Forest Service's Draft of Environmental Impact Statement from August 2026.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas I am commenting on span Arizona, Utah, and Florida, and the agency's proposal to rescind the 2001 Roadless Area Conservation Rule would affect every one of them. I want the record to reflect what is at stake in each place and why the supporting analysis does not hold up. The Ocala National Forest in Florida sits directly on top of the Floridan Aquifer. Alexander Springs, a first-magnitude spring in the heart of the forest, pumps 80 million gallons of crystal-clear water per day through karst limestone that makes any road construction a direct contamination pathway to the drinking water supply of central Florida. The roadless areas of the Ocala total 4,855 acres, and the species that depend on them include the Florida scrub-jay, found nowhere else on the planet, the Florida black bear, the red-cockaded woodpecker, the gopher tortoise, and the eastern indigo snake. Red-cockaded woodpeckers recovered here from 7 breeding pairs to 98 family groups because the longleaf pine stands they need have never been fragmented by roads. Rescission puts all of that at risk for a state whose karst hydrology has no tolerance for the sediment and contamination that road-building brings. The agency should explain, specifically and on the record, how it evaluated the aquifer recharge function of the Ocala roadless acres and what mitigation, if any, it believes adequate for karst terrain. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres, including the Coconino Rim in the Kaibab National Forest and Black Canyon in the Prescott National Forest. Across the Southwestern region, which includes Arizona, 739 municipal water intakes sit in watersheds containing affected roadless areas. The proposal justifies rescission partly on wildfire and fuels management grounds, but the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency must 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, and explain why it is departing from its own prior findings. The economic case for rescission does not survive contact with the agency's own numbers. The 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." 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. That range does not establish a net benefit. The proposal also expands a road system already carrying a $6.9 billion maintenance backlog. The agency should explain, with specificity, how an action whose own analysis cannot confirm a positive net value justifies that expansion. The proposal certifies no significant impact on small entities while simultaneously naming outfitters, guides, and tour operators as affected businesses in the DEIS and booking lost recreation benefit at a minimum of $6.1 million a year in the Cost Benefit Analysis. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally rather than assessing the guides and outfitters actually holding permits in the affected areas, and it concedes some of those firms may lose those receipts. That is not a serious analysis of small-business impact. The agency should withdraw the certification and assess the impact on the specific small entities operating in or adjacent to the affected roadless areas, Fishhook in the Dixie National Forest among them, rather than averaging the harm away across the national sector. Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is such an interest. The rule has been in place long enough that planning, investment, and permitting decisions have been made in reliance on it. The agency invited these interests into the record and then provided no mechanism for weighing them. I ask that it actually identify and assess the reliance interests described in the comments it receives, including this one, before any final action is taken. Sincerely, Katherine Piehl Phoenix, AZ

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Coconino Rim is where I woke up to birdsong and watched sunlight rain down through the trees. I ran the trails that crossed the forest there in 2018, and I was pleased and surprised by the varied plant-life and birds I found. That quiet beauty is what I am writing to defend. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask the agency to answer the specific questions below. The Coconino Rim covers 7,213 acres in the Kaibab National Forest in Arizona. The birds I encountered there are precisely the kind of wildlife the agency's own record shows roadless protection serves. The DEIS cites findings 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, with 31 percent of species avoiding the noise entirely. If roads are opened into the Coconino Rim, the birds that made those mornings memorable face exactly the pressures the agency's own science describes. I ask the agency to explain what weight it gave these findings when evaluating the biological consequences of rescission for inventoried roadless areas like this one. The agency frames part of this proposal around wildfire and fuels management. Its own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency has not reconciled that finding with the direction this proposal takes. I ask that the agency explain, in its response, why the proposal departs from these prior findings and how it accounts for the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. That ignition data deserves its own attention. The DEIS states that human-caused ignitions increase in abundance with proximity to roads. The agency has not quantified what new road access in currently protected areas would mean for fire frequency, nor has it weighed that expected increase against whatever wildfire hazard reduction it claims to achieve. The agency should provide that quantification and that weighing before any final action is taken. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres, and across the Southwestern region, which includes Arizona, 739 municipal water intakes sit in watersheds containing affected roadless areas. The proposal's regulatory flexibility analysis reaches a no-significant-impact conclusion by spreading losses across every small firm in the relevant sector nationally, rather than assessing the outfitters, guides, and tour operators actually holding permits in places like the Kaibab. The agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year and concedes some firms may lose those receipts entirely. 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. That certification cannot stand alongside the analysis that accompanies it. The agency should withdraw it and assess the impact on the small entities actually operating in the potentially affected roadless areas. The proposal itself invites comment on reliance, stating it solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My visit to the Coconino Rim and every plan I and others form around the continued protection of places like it represent exactly the kind of reliance interest the agency has invited but not assessed. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds. Protect the Coconino Rim and Arizona's other roadless areas for the people who will come after me hoping to find the same quiet mornings I found there. Sincerely, Laurie N Lakewood, CO

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The public lands of Northern Arizona are where my family spends a significant amount of time. We hike in the Flagstaff Forest for recreation, and we look for owls, deer, and other wildlife. I believe public land should be managed for conservation, recreation, and ecology. The Coconino Rim roadless area in the Kaibab National Forest is part of that landscape. The proposal to rescind the 2001 Roadless Area Conservation Rule would put all of it at risk, and the agency's own analysis gives me no confidence the rescission is justified. The wildfire rationale troubles me most. The agency's proposal invokes fuels management as a reason to open roadless areas to new road construction, but its own record states plainly: "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." I hike and spend time in Northern Arizona forests that face serious fire risk. Roading those areas to reduce that risk is contradicted by the agency's own findings. I ask that the agency explain why the proposal departs from those prior findings and reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The deer we look for in these forests depend on unroaded habitat. The agency's own analysis, citing Sawyer et al. 2013, finds that roads built for extraction may alter mule deer migration routes and increase movement speed. The Tribal Summary Impact Statement credits the rule's protection with the recovery of deer and moose populations in Alaska by preserving old-growth winter shelter. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres. Rescission puts the security and connectivity that sustain deer populations across all of that land at risk. The agency must account in its final record for these specific, documented findings about deer and unroaded habitat. The agency's legal authority argument fares no better than the wildfire rationale. A reviewing court's own words: "Exercising jurisdiction pursuant to 28 U.S.C. § 1291, we REVERSE the district court’s order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit held that the 2001 rule was within the authority Congress granted and did not create de facto wilderness. The proposal reasserts doubts about statutory authority that courts already resolved. I ask that the agency address that holding directly and explain on the record the legal basis for any contrary position. Finally, this comment is itself evidence of reliance. The agency's own solicitation requests "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My family has organized recreation and time in Northern Arizona public lands around the protection the 2001 rule provides. That is a reliance interest the agency invited and then declined to measure. The agency should identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Kristen and Greer Morgan Los Angeles, CA