Read the comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Absaroka and Beartooth Mountains in Montana are some of the most wild country in the US. They are humbling and beautiful, and they allow the wildlife of the Greater Yellowstone Ecosystem to thrive. I hike, backpack, and camp there and in the Pioneer Mountains and the Mission Mountains of western Montana to ground myself, to reset my nervous system from the manic pace of the modern world. These places have shaped how I think about public land management. I oppose the rescission of the 2001 Roadless Area Conservation Rule in Docket FS-2025-0001. Public lands should be managed for every being, from humans to animals, insects, fish, and plants. All of them deserve to be protected. Montana holds 235 inventoried roadless areas totaling 6,395,392 acres. The Custer Gallatin Forest accounts for 848,000 acres, forms the northeastern wall of the Greater Yellowstone Ecosystem. Grizzly bear, Yellowstone cutthroat trout, wolverine, elk, and bighorn sheep all depend on that country staying intact. I have backpacked in the West Pioneer roadless area within the Beaverhead-Deerlodge for years. It is peaceful and wild and deserves to remain so. In the Mission Mountains, the western flank carries the first Tribal Wilderness, managed by the Confederated Salish and Kootenai tribes to protect natural and cultural resources, and the adjoining national forest sustains grizzly bear habitat and Native food plants. The Kootenai National Forest, which borders this landscape, holds 48 inventoried roadless areas totaling 638,470 acres and is home to the Cabinet-Yaak grizzly population, one of the most endangered in the country, with fewer than 50 bears surviving there. Every road opened is a mortality risk for that population. The agency's own record is clear on what roads mean for bears. The DEIS quotes the federal grizzly recovery plan to state 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. I ask that the agency address, specifically and in writing, how the proposed rescission can be squared with its own grizzly recovery record and with the documented mortality risk that attaches to road access in Cabinet-Yaak and Greater Yellowstone grizzly habitat. The west is arid. I regularly recreate in the Forest that supplies my city's water, and I know we need to protect the clean water we have left like our lives depend on it, because they do. Across the Northern Region alone, which includes Montana, 1,287 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis states that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency must explain what it intends to say to the communities whose intakes draw from these watersheds, and it must do so on the record. The agency justifies rescission in part on wildfire grounds, but 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 must explain why the proposal departs from these findings and reconcile the claimed fuels rationale with its own ignition data. The economic case for rescission is not established by the agency's own numbers. The agency's Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, and the existing road system already carries a $6.9 billion maintenance backlog. The agency must explain in plain terms how a proposal whose own analysis cannot establish a net benefit justifies adding to that backlog. 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 was reached by spreading losses across every small firm in the sector nationally rather than assessing the permit holders actually operating in the affected areas. The agency must withdraw that certification and assess the impact on the small businesses actually holding permits inside the potentially affected roadless areas. 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 agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. Sincerely, Nicki Jimenez Bozeman, MT

I live in Beacon, New York and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking. We have so few undeveloped spaces. We need to protect this land that makes America truly great. Northwest Peak is one place that has shaped my views on this proposal. It is within the Northwest Peak Inventoried Roadless Area in Kootenai National Forest. The gorgeous isolation and beauty of this untouched land. I am concerned about wildlife habitat and landscape connectivity. We have so few truly wild spaces. Our natural ecosystem is depending on keeping these spaces free from human intervention. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

I am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking, trail volunteering, wildlife watching, and living in or near a National Forest community. I value places that can be preserved in their natural state for future generations. Ten Lakes Basin is one place that has shaped my views on this proposal. It is within the Ten Lakes Inventoried Roadless Area in Kootenai National Forest. Relatives live nearby and we want this space to be preserved. I am concerned about wildlife habitat and landscape connectivity; roads can fragment habitat and increase human access with negative consequences to wildlife. I am concerned about clean water and healthy watersheds. Roads require drainage systems, culverts, stream crossings, and ongoing maintenance. Poorly located or maintained roads can contribute sediment to streams and affect aquatic habitat. This is troubling to me. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

I live in St. Louis, MO and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking, camping, and operating or working for a business connected to public lands. I grew up near the PNT with my scout troop and found those experiences to be foundational my upbringing. I want others to have that same opportunity to be in remote and wild spaces. Ten Lakes Basin is one place that has shaped my views on this proposal. It is within the Ten Lakes Inventoried Roadless Area in Kootenai National Forest. I remember having a great weekend of backpacking and swimming with my scout troop. I am concerned about clean water and healthy watersheds. Roads can divert streams or water supplies, requiring culverts and maintenance. It also results in runoff or erosion potential. Roadless areas matter to me for recreation and the experiences they provide. Roadless landscapes allow people to truly have outdoor wilderness experiences that are harder to come by in roaded areas. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

Dear Forest Service, I am writing to you in support of retaining the Roadless Rule as is, and in opposition to eliminating the Rule. My reasons are mostly all the ones that you have heard before, and all are perfectly legitimate and true:  Roadless areas (RA’s) constitute vital wildlife habitat  They are sources of pure rain and snowmelt water for wildlife, humans, fisheries  They are valuable for human recreation, such as hiking, berry picking, birdwatching  Considering that most fires are started in the vicinity of roads, retaining RA’s actually prevents fires  Keeping RA’s roadless eliminates many of the other problems caused by roads, such as erosion, habitat fragmentation, weed invasion But I have specific reasons, based on where I live, in the Yaak Valley in far northwest Montana, for championing our RA’s. One of those reasons is that they are a favorite hangout for the local population of threatened grizzly bears, and the place where they are safest. Just as most fires start in proximity to roads, most bears that are shot by humans, whether accidentally or on purpose, are shot close to roads. And bears are not the only ones seeking safety in RA’s. Here in the Yaak, in the Kootenai National Forest, an RA is the only safe place for a tree. By that I mean that virtually all the rest of the forest either has been logged or can and will be logged. Since our national forests are supposedly public forests and owned by you and me, and since they are supposedly managed for “multiple use,” how is it fair or right that one use is predominant over all the others and nearly universal throughout? That use, of course, is logging. Except for the roadless lands and scattered tracts of old growth—about 10% of the Forest-- the rest has been relentlessly roaded and logged for most of the last 70 years. Maps of past harvest activities on the Kootenai, including the Yaak area, reveal a landscape fragmented into thousands of patches representing timber cutting units accessed by thousands of miles of logging roads. To find natural, intact forest land in the Yaak, one has to visit one of our roadless areas. Eliminating the Roadless Rule, as the Forest Service apparently is poised to do, would open even those lands to logging. For all these reasons, our IRA’s are not only ecologically significant, they are also, to me and many others, precious and irreplaceable parts of our landscape. Sincerely, Pamela Fuqua

I am writing in opposition to the proposed 2001 Roadless Area Conservation Rule Rescission. I am a concerned citizen who enjoys recreating on public lands and who cares about the ecological integrity of these lands. I have also worked on trails in Kootenai National Forest as a former member of the Montana Conservation Corps. Given the information provided in the Draft Environmental Impact Statement (DEIS) for the proposed rescission, the reasons for it as published by the USDA are misaligned with the predicted consequences of the rescission. The stated purpose and need for it is to return “decision-making authority to local leaders [to ensure] that issues such as reducing wildfire risks and forest health are addressed based on local conditions rather than a one-size fits all regulation,” however, this action would threaten forest health and exacerbate wildfire risks by putting pressure on rural, local decision-makers who may feel a responsibility to open up lands to irresponsible developments for short-term profits. In the wake of budget cuts to healthcare, food programs, and education, more jobs will be needed to help support rural families and communities, which logging operations and construction projects could potentially provide, but this would come at the cost of worsening long-term environmental conditions. The DEIS states that developments such as constructing new roads, increased timber production, oil, gas and new mining projects would likely result in “increased fire frequency (human-caused), reduction in primitive or semi-primitive recreational settings; sedimentation and impacts to water quality; landscape fragmentation; adverse impacts to threatened, endangered, or sensitive wildlife and plants; loss of scenic character; impacts to tribally important resources; or economic losses related to recreation or non-commodity values of roadless areas,” (22). These effects will be proportionate to how much development occurs and how much mitigation is done to prevent the worst outcomes. This is why the DEIS calls for an increase in forest health management activities if the rescission occurs. However, these kinds of operations seem less likely to occur than ever due to recent and expected budget cuts and layoffs to the Forest Service. Therefore, this rescission should not occur at all, but especially so if there is no commitment, insufficient manpower in the service, nor an actual plan with funding laid out as to how negative impacts can be effectively managed. I fear that this rescission will likely have devastating impacts on those who live near and depend on healthy forests for their own survival, livelihoods, and for a sense of identity and meaning. It would diminish or entirely eliminate the quality of the last remaining places where you can get away from the modern world and explore how wondrous, awesome, and terrifying nature can be. I have found some of these lands to provide great spiritual satisfaction and to destroy them as if they were just an economic resource is, to me, like burning a church or tearing down a temple. We know that new road construction and timber harvesting done irresponsibly is destructive to overall forest health, and so we should not renege on the roadless rule which offers widespread protections from destructive developments across public lands. I would be more favorable to a rule change rather than an entire rule rescission that, all at once, gets rid of protections that have been in place for 25 years. Why can’t we expand operations that are explicitly for the purposes of fire safety, vegetative management, habitat improvement, and any other forest health concerns without at the same time opening our forests up to more industrial activities, and thus to damaging our remaining forests? The reasons for this rescission do not make any sense to me. You say you want one thing, that is, returning decision-making powers to local land authorities in order to be better able to preform forest health operations, but then, in the same move, you are doing something completely antithetical to the purposes of improving forest health, that is, opening public lands to more industrial logging, mining, and construction activities. This misdirection, lying, and deception makes me furious at the whole situation. Stop selling out the American people. Do your jobs as representatives of the American people. Prioritize and protect us and our lands, do not get rid of the 2001 Roadless Rule.

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

The proposed 2001 Roadless Rule Conservation Area Rescission Draft Environmental Impact Statement fails the Administrative Procedures Act and “hard look” requirements because NEPA has not been adequately completed to analyze the effects of the proposed rescission on the human environment. There is no adequate or current map for the NFS motor vehicle use system for neither the Department nor the public to account for current roads or the density of roads in inventoried roadless areas. As established by Center for Biological Diversity v. USFS (9th Cir.), in which the U.S. Court of Appeals for the Ninth Circuit ruled on a consolidated appeal concerning the Black Ram Project in Montana's Kootenai National Forest, agency decisions must account for unauthorized or user-created roads and consider them when analyzing for effects of motor vehicle use on natural resources in NFS lands. The presence of these roads, while illegal, is widely known. The Ninth Circuit's decision makes it clear that the agency must consider such roads in metrics analyzing effects and the degrees of such effects of the proposed action. Given that there is no mapping to that extent, or other materials that would provide evidence that such roads were accounted for in effects analysis, the Department has not presented sufficient analysis of reasonably foreseeable effects of the proposed rescission in the DEIS. By conducting analysis under an EIS, the Department anticipates that significant effects to the environment are likely. Such effects merit a review of project impacts that are informed by contextualizing the proposed action within the overall condition of the human environment. Activities in a project’s vicinity, such as user created roads and trails in which motor vehicles can be used, are relevant to the analysis of the reasonably foreseeable effects of this proposed rescission per recent case law (2025). The DEIS does not provide this information, and thereby fails the Administrative Procedures Act and “hard look” requirements without such mapping and accompanying analysis. In summary, there is not sufficient analysis for the Department to move forward with altering the 2001 Roadless Area Conservation Rule. Sincerely, Amy Mayedo

Dear Whoever, I serve on the board of the Yaak Valley Forest Council (YVFC) in northwest Montana, an organization founded in 1997 whose mission has focused on preserving the Roadless Areas (RA’s) in the Kootenai National Forest, and particularly in the Yaak River watershed. The Yaak’s RA’s largely consist of what was left over after the lush forests at lower elevations had been clear-cut, that is, the mountain tops. That is not say that there are no resources worth pursuing within RA’s in general, but for the most part, the biggest and best timber was never to be found in the Yaak’s RA’s: if it were, they would not be RA’s. We value our RA’s precisely because they are roadless. With roadless-ness comes solitude, quiet, a sense of wildness not found where logging roads and old and new timber cutting units dominate the landscape. In the Yaak many of our hiking trails leave the valley floor and proceed up to the top of a ridge or mountain. As you gain elevation, you cross one logging road after the other after the other until you have crossed the last one shown on your map, and know that you are entering a different kind of space, an intact forest. For RA’s are not just areas without roads: they are areas without stumps and without weeds. This latter, the lack of invasive plants, is crucial. For logging roads serve as conduits of invasive plants far into the back country. I have walked for miles on logging roads that have been closed to vehicular traffic for decades, and failed to outwalk the hawkweed, knapweed, oxeye daisy that have taken permanent possession of the disturbed ground in and between the tracks. Another of the main objectives of YVFC is preservation of the precarious grizzly population in the Yaak, which numbers 25-30 bears—a count that has not increased since I moved here a quarter century ago. This number needs to increase if the population is to remain viable. But it has not increased because people keep killing bears. And most of the bears that are killed, are killed in the vicinity of roads. A strong correlation exists between open roads and dead bears. Thus, our grizzly bears need habitat that is either roadless or where roads are closed to vehicular traffic. One of the arguments we hear in favor of doing away with RA’s is that roads are needed for the purpose of fighting fire; however, the reasoning behind this claim is exactly backwards to the real life situation. Research conducted by the United States Forest Service (USFS) itself revealed a robust link between roads and wildfires, with most ignitions occurring within 164 feet from a road. In other words, the reasoning must go, that you need roads to combat fire that would probably not have occurred in the absence of roads?? And really, how many more roads do we need in our public forests? It is often cited that the current milage of roads in all lands managed by the USFS is estimated to be 370,00-380,000 miles, or enough to encircle planet earth 15 times. But another way to look at this, which is rarely considered, is the actual area in square miles of the forest that is displaced by roads. Using 20 feet as a conservative estimate of the average width of a roadway—from trees on one side to trees on the other—and a length of 375,000 miles, you arrive at a total area of about 1,300 square miles. This is approximately equal to the area of the state of Rhode Island, or of Yosemite National Park. How many of these roads were built to current standards is also a good question, but I can say for certain that some in the Yaak were sloppily constructed in order to quickly facilitate logging operations, and continue to bleed sediment into our watershed even after decades. But even the “good roads” spread weeds, fragment wildlife habitat, constitute a danger to bears and are associated with wildfires. The current plan to do away with the Roadless Area classification on the public’s forest lands strikes me as ideologically, rather than practically, motivated. It appears to me to be yet another element of a broad anti-environmental agenda that neither I nor most other Americans support. It is beyond nonsensical: it is antithetical to responsible ecosystem management, and just plain wrong. Sincerely, Mary Campbell

I live in Lolo, Montana and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking. Getting out where it is just us and creation with no noise, no sounds but those which are natural to the woods, is such an important reset for my hiking group and I! Ten Lakes Basin is one place that has shaped my views on this proposal. It is within the Ten Lakes Inventoried Roadless Area in Kootenai National Forest. Quiet, pristine, far from the hustle and bustle of life. I am concerned about wildlife habitat and landscape connectivity. Large roadless landscapes can provide relatively intact habitat and connections between protected areas. Roads can fragment habitat and increase human access. I am concerned about clean water and healthy watersheds. Roads require drainage systems, culverts, stream crossings, and ongoing maintenance. Poorly located or maintained roads can contribute sediment to streams and affect aquatic habitat. I am concerned about increased timber-development pressure in currently roadless areas. Removing the national safeguard while timber-production pressure is increasing could put roadless lands at greater risk. Before rescinding the national rule, I would like USDA to answer this question: How would USDA ensure that roadless values are protected through individual forest plans and project-level decisions if the national rule is removed? I am concerned about wildlife habitat and landscape connectivity. Large roadless landscapes can provide relatively intact habitat and connections between protected areas. Roads can fragment habitat and increase human access. I am concerned about clean water and healthy watersheds. Roads require drainage systems, culverts, stream crossings, and ongoing maintenance. Poorly located or maintained roads can contribute sediment to streams and affect aquatic habitat. I am concerned about increased timber-development pressure in currently roadless areas. Removing the national safeguard while timber-production pressure is increasing could put roadless lands at greater risk. Before rescinding the national rule, I would like USDA to answer this question: How would USDA ensure that roadless values are protected through individual forest plans and project-level decisions if the national rule is removed? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

I thank you for this opportunity to comment on the proposed rescission of the 2001 Roadless Rule by the USFS. I am a lifelong resident of New Hampshire. Having spent much time in the forest at an early age it made sense to study forestry as a science at the University of New Hampshire, where I graduated with a Bachelor of Science degree in forestry in 1975. From 1971 to 1975 I was a part time USFS employee in the White Mountain National Forest in New Hampshire and the Kootenai National Forest in Montana in 1975. Without the possibility of full time USFS employment two friends with forestry degrees and myself started a private forestry consulting firm (Forest Land Improvement) in New Hampshire in 1975. It evolved into a multifaceted business covering all aspects of forest management activities including USFS contract work covering mostly timber stand improvement. The business became a corporation which I owned for the prior 5 years to my retirement in 2020. The business continues today under new ownership, providing continuity to the many clients using its forest management services. My total time of employment in this firm was 44 years. I have given a great deal of thought about the roadless rule rescission. I am against this and will list a few reasons. ~We are experiencing more severe weather events particularly rain in the WMNF. Accessible roads have washed out and there is not enough money in the budget to fix them. Do not open more roads until you can pay for the ones that you have a legitimate right to use. ~Much of the 2001 roadless areas have had timber stand improvement work following extensive cutting in the past. This growing stock will not be ready for intermediate, low value thinnings for another 20+ years and maturity for another 50+ years. There will not be enough income to pay for reopening and or constructing new roads. ~The roadless areas lie with the upper elevation limits of the forest. The forest growth in this area is a buffer zone for rainfall runoff thus protecting the soils from severe erosion. Its this erosion that can potentially pollute potable water sources and destroy aquatic habitat. ~The intrinsic value of knowing there are areas on our national forests that are still wild provides a physical and emotional attachment for the people of this country both forest users and non users to a time when our country was being first settled.

I live in Corvallis, Oregon and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking. Having natural spaces untouched by human infrastructure development is crucial not only for ecosystem health but also for allowing people to connect with the earth, improving both physical and mental health. Northwest Peak is one place that has shaped my views on this proposal. It is within the Northwest Peak Inventoried Roadless Area in Kootenai National Forest. My time hiking on Northwest Peak was one of the most memorable experiences on the Pacific Northwest Trail. I began the hike full of doubt, but a sky full of stars glowing in a golden sunset allowed me to reset and find the ground. I am concerned about the cost of expanding the National Forest road system. There is not only an immense financial cost in building and maintaining roads, but also a huge cost to the ecosystems that are disrupted by development and increased human traffic. I am concerned about wildlife habitat and landscape connectivity. Forest fragmentation has a significant impact on wildlife and the degradation of forest habitat. I am concerned about clean water and healthy watersheds. Increased human traffic in wild areas will add nutrients and sediment to streams and rivers, affecting downstream ecosystems, including agriculture, fish, and other aquatic animals. I believe maintaining a national conservation baseline matters. The beauty of these natural areas cannot be replicated, regrown, or replaced by a form of human development. These areas have developed over geological time frames, and ignorant human activity in the name of short-term gain has no place without careful ecological consideration. Before rescinding the national rule, I would like USDA to answer this question: How would USDA account for the long-term cost of maintaining, reconstructing, and eventually decommissioning additional roads? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

Hi there, My name is Emma Grusing and I strongly oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I have been living and working in rural western Montana for the last decade, in many areas that would be devastated by the rescintion of this rule. Over 6 million acres of Montana forests are protected by this rule! I have worked the U.S. Fish and Wildlife Service, the National Park Service, state wildlife agencies, and non-profits centered around caring for the plants and animals across the landscape. The forests of Northwestern Montana are some of the most incredibly beautiful areas in our country and are incredibly special to me. Building more roads throughout these forests would create devastating affects on water quality, land stability, wildlife, and native plants. There are many rural towns near roadless areas across the country that rely on these areas for clean drinking waters, and building roads would degrade that quality and quantity singificantly. Clean drinking water is a basic human right our government should bo happy to provide its citizens. Moreover, the United States is unique in that we have so many roadless areas that are still largely untouched by extractive resource practices. This benefits the amazing wildlife we still have as compared to countries in Europe where their native wildlife has been stripped away time and time again, with many species going locally instinct in several areas across the continent (i.e. wolves and brown bears across England, Ireland, and Scotland). An increase in roads and construction will interrupt the life cycles of our beautiful wildlife (lynx, bears, wolves, amphibians, birds, etc). Not to mention, the rescintion of this Rule will irrevocably damage habitats that are already under pressure in a changing climate. Kootenai National Forest in northwestern Montana is a prime example of all I said above. This forest is logged, yes, but the increase of roads for logging would be catastrophic for the ecosystem. The Yaak river area of the Kootenai national forest is nearly a rainforest and encompasses so much natural beauty that would be a devastating loss in the building of more roads for increased logging. I urge you to keep the Roadless Rule in place. The rescintion of the rule will not protect us from wildfires. 90% of wildlife start near roads and are 4 times more likely to start near roads, so logically, an increase in roads will equal an increase in fires. The Centennial Mountains and the Gravelly mountains of southwestern Montana are two more places that are home to me and are protected by the Roadless Rule. The areas are already experiencing drought and building more roads through the wilderness would be devastating. This area is so remote and acts as a wildlife sanctuary. Degrading water quality, increasing human disturbance, increasing wildfire risk, and decreasing access to public lands are all at risk if you rescind this rule. I would also implore you to consider Indigenous cultural values of these protected lands. These are areas where Indigenous peoples have traditionally resided for thousands of years, and they still have traditional sources of foods, fibers, and medicines that would be stripped away in the rescintion of the Roadless rule. The last thing I would like to mention is the fact that we as Americans have a right to our public lands. We have a right to retain the natural beauty of our public lands. We have a right to access our public lands and have them managed in a way that benefits us, the wildlife, and the plants. Building more roads for increased logging is not the way. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake. I strongly oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative. Please keep it in place for the health and safety of our future generations. Thank you, Emma Grusing

Dear Forest Service,
 I write to urge you to maintain the the 2001 Roadless Area Conservation Rule (2001 Roadless Rule), as it currently exists, keeping the broad prohibitions on road construction, road reconstruction, and timber harvesting that are currently in place. Roadless wilderness is crucial for protecting wildlife, protecting the sources of clean drinking water, and maintaining old growth forest that captures carbon in ways that younger woods cannot and contains complex and irreplaceable biodiversity. Once a road is built in one of these areas, the chances of the area being disturbed in further and detrimental ways is high. But even one road in the midst of a wilderness area does irreparable harm. As a hiker, river rafter, and camping enthusiast, I am especially concerned with maintaining the pristine wilderness with United States is lucky to have. I’m particularly concerned about and attached to the Shawnee Forest in the southern part of my own home state of Illinois, and also the Kootenai National forest in Idaho and the Olympic National Forest in Washington State, where my family and I have spent many vacations and had life changing wilderness experiences. Any supposed economic benefit from rescinding the roadless rule would be outweighed by the many costs. The maintenance needed on the 368,000 miles of roads in America’s national forests was one impetus for the Roadless Rule in 2001. Roads in these wilderness areas are extremely expensive to maintain, and the economic analysis that the recession proposal is based on is flawed because projected timber revenues cannot cover the massive costs of building and maintaining new roads in remote forests. There would also be significant economic impacts to businesses that connect people with wilderness experiences. Wilderness outfitters and guides operating under special use permits would see a great deal of lost revenue due to changes in landscape, recreation quality, and wildlife habitats. Most important are the non-commodity values that roadless areas provide. These values pertain to the ecological, recreational, passive use, and aesthetic benefits of roadless areas and include things like the conservation of plants, animals, air and water quality, a desire to experience solitude and personal renewal in wild areas, a sense-of-place attachment to a specific area, the desire to leave a legacy of natural areas for future generations to experience and benefit from. Both the economic and non-commodity value of well-functioning ecosystems and biodiversity are tremendous and difficult to accurately measure.. Please maintain the roadless rule and protect our nations old growth forests and back country wilderness. Future generations as well as Americans of today are counting on you. Sincerely, Elizabeth Majerus Urbana, Illinois

I value roadless areas because they provide wildlife habitat, clean water, and places where I like to hike, fish and experience roadless natural areas. Specially I’ve spent time in the Kootenai National Forest, Idaho Panhandle National Forest and Bitterroot National Forest. I’ve dedicated my career to natural resource management and understand how valuable these roadless areas are for wildlife populations. I strongly oppose removing the 2001 roadless area conservation rule. If this rule is removed this will affect Grizzly Bears, Salmon, Scrub jays and countless other species who depend on these intact habitats for survival.

A generation ago, in defending the portfolio of roadless lands in the public domain, writers from each of the 50 states published op-eds in local newspapers in each state. Mary Stegner defended the nation’s roadless lands in California, and Bill McKibben, Vermont’s, and so on. The unanimity of the campaign was profound—there may be no more patriotic or common ground issue than Americans’ love for the land where we live—the homeland—and the Clinton administration’s commitment to public engagement on this issue was rewarded with overwhelming number of comments in favor of keeping roadless lands roadless. The fact that the lands that were roadless then still are roadless is testament to two things: the efficacy of the Roadless Rule, and the geographic fact that the vast majority of those lands were roadless because of their inaccessibility. A vindicative Trump administration, willing to subsidize those industries it finds ideologic favor with, is bent on destroying the country’s laws and finances while rewarding his family and lamprey-associates with the spoils of democracy. Nor is his game plan original in the annals of U.S. history. This is an attempt to kill that which his opposition finds sacred—an American civil warfare dating back to the genocide of America’s first people: kill the buffalo to kill Indigenous communities. Trump’s overreach however has given us the opportunity to reiterate our nation’s passionate commitment to defend the land we stand on. Trump was turned back in Texas, when he tried to send bulldozers into Big Bend National Park, and last year when he tried to begin selling off our public lands to private developers. It’s puzzling that these roadless lands in question are managed—theoretically safeguarded—by the Department of Agriculture, a curious assignation, particularly here in the northern Rockies, where forests such as the ancient inland rainforests of the Yaak Valley, on the Kootenai National Forest, can literally take millennia to develop to full biodiversity. Wild forests are but a crop, but a miracle. They store massive amounts of carbon and are of the headwaters of the majority of municipal water supplies in the West. It's the summer of The Odyssey. The challenges befalling our nation seem Odyssean. Public roadless comments are due August 21. In typical fashion, the administration is sending out rule-change proposals in waves, with due dates for comments only days apart. For instance, lobbyists in D.C. are proposing changes to the National Travel Management Plan that will degrade wildlife habitat on lands where roads already exist. There would be an abdication of responsibility for keeping closed roads closed. In essence these two rules pave the way for all national forests to have roads built anywhere, any time, and at any expense. We-the-taxpayers are already reeling from Trump’s military misadventures and $40 trillion deficit. On the Kootenai National Forest, for instance, there are an estimated 10,000 miles of road. Do we really need any more?) In the novel Cold Mountain, the character of Ruby, upon gazing out at a Civil War abomination, says fiercely, “God won’t stand for this war long.” Regardless of one’s religious leanings, it’s a sentiment shared increasingly by a nation under siege, and a democracy in deepest peril. The administration still hasn’t learned what Ed Abbey articulated and what we know as an article of faith: in Montana, we stand for the land we stand on.

I live in Wayne, PA and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking and camping. Roadless is more wild and therefore more natural. Keep the roadless rule intact. Ten Lakes Basin is one place that has shaped my views on this proposal. It is within the Ten Lakes Inventoried Roadless Area in Kootenai National Forest. It's such a beautiful area. Unspoiled and worth the effort to get there. I am concerned about the cost of expanding the National Forest road system. The ForestbService is already underfunded and it's beginning to show in the National Parks. Adding more to manage is foolish. I am concerned about wildlife habitat and landscape connectivity. Habitat is fragile, plants, animals, watersheds need to remain undesturbed. I am concerned about clean water and healthy watersheds. Glyophosphate is being used to manage plant growth. Only one example of how roads impact watersheds. I am concerned about increased timber-development pressure in currently roadless areas. Timber is important, but it ruins the land for decades. We don't need more timbering land. I believe maintaining a national conservation baseline matters. Administration priorities should not be dictating common sense conservation policy. Before rescinding the national rule, I would like USDA to answer this question: How would USDA account for the long-term cost of maintaining, reconstructing, and eventually decommissioning additional roads? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

Hello, I live in Alberta, Canada but my partner and I have spent time in Oregon, Montana, California and Washington. We’ve spent time camping, hiking and exploring in a couple different Roadless areas. Specifically Olympic national forest area, and the Kootenai National forest. I’m scared that rescinding the roadless areas are going to have a negative impact on my ability to continue exploring as well as have a negative impact on the wildlife that call these areas home. Thanks for considering my message before you make a decision. Concerned outdoors woman, Kaitlan Titford

A decision ro rescind the roadless rule should come with a large appropriation or it is bogus. We have a roadless area next to our Montana ranch. Building roads into kt or logging it would require millions in road construction costs, because it is landlocked by private land, as is a lot of the checkerboard land. Our forest road experienced a washout kf bridles in 1971. They never replaced the bridles, but the county. Finally replaced two of the four bridges to provide residential access…in 2021(50 years later). Our local national forest (Kootenai NF) sold all its road maintenance and road building equipment in the seventies..so: Who is going to build and maintain new roads into marginal and landlocked forest services lands. Counties are strapped for funds. Even if logging companies build roads, no public entity has the funds to maintain them. Our primary access from the south is the Vermillion River Road. It hasn’t seen a grader in at least en years and is becoming a four wheel drive road.. it is a primary access to two Forest Service campgrounds. Following last years epic windstorms on the Kootenai miles of roads were littered with blowdown. Many of those roads also habpve washouts. No one has the funds to open those roads…private folks are trying to cut them out. Please try to mange your exisiting road system better before you contemplate new roads. Dr Dan Green Forest Economist