Read the comments.

I submitted comments to the proposed rule in Sept 2025. Attached below. Consider these integral to my current comments. I strongly oppose recission of the 2001 Roadless Rule. I served on the roadless rule Content Analysis Team (CAET) in 2000, we read and synthesized all comments. Sentiment strongly favored protecting roadless areas and benefits they provide: clean water, biological diversity, wildlife habitat, forest health, and recreation. Climate change and population growth have increased support for roadless areas. I worked on the WMPZ Forest Plan Revision Team for forests in Western Montana; Flathead, Lolo, and Bitterroot. Despite efforts and substantial expense by American taxpayers, these were shelved due to a national lawsuit. Courts ruled the 2005 planning rule was inconsistent with the National Forest Management Act. The Flathead National Forest completed its forest plan revision in 2018 under the 2012 planning rule. My September 2025 comments must be considered in conjunction with my current comment for 53828 Federal Register/Vol. 91, No. 160/Thursday, August 20, 2026/Proposed Rules, which states, “As resource conditions and national policy have evolved, the Department has determined that a single, national blanket approach to the management of inventoried roadless areas taken in the 2001 Roadless Rule constrains responsible officials from exercising the timely, place-based discretion needed to meet the Forest Service’s multiple-use mission.” NOTE: While the 2001 roadless rule constrains officials from exercising their absolute place-based discretion, it does not follow such discretion is needed to meet the Forest Service’s multiple-use mission. On the contrary, NFMA was driven by management skewed to commodity production over multiple use values: watershed, wildlife, wildlands, recreation. Conditions on the Bitterroot amd the Monongahela national forest were evidence a more balanced approach was needed, resulting in NFMA. “In addition, evolving national priorities and changed conditions have required more active management approaches. The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which in turn has contributed to challenges in addressing forest health concerns.” NOTE: See pg 8 from my 2025 comments for a research being done. There are volumes that dispel lack of active management as a driver of forest health concerns. On the contrary, there is evidence forest management itself fosters such concerns. “This proposed rescission is intended to return primary authority for determining the appropriate management of inventoried roadless areas at the local level to the land management planning process mandated by the National Forest Management Act of 1976 ……The National Forest Management Act establishes the requirement for the Forest Service to develop land management plans, including direction in 16 U.S.C. 1604(a) and (b) for interdisciplinary planning and consideration of landscape-level conditions. These statutory requirements are implemented through the Agency’s land management planning framework, which require consideration of the plan area in the context of the broader landscape and requires that each plan reflects the unit’s expected distinct roles and contributions to the local area, region, and Nation. “ NOTE: Interdisciplinary planning and consideration of landscape-level conditions was done on the Flathead NF and ongoing revision on the Lolo NF. Refer to my Sept 2025 comment using Flathead as an example. Of 500,000 roadless acres, fewer than 200,000 remained. The rest were assigned management areas based on conditions and public input. Decision-makers balanced conflicting uses and devised management area prescription for roadless areas. “At the same time, this planning approach allows for place- based, collaborative decisionmaking that is responsive to specific on-the- ground resource conditions, rather than a ‘‘one-size-fits-all’’ national mandate. While national-level considerations are important, land management planning efforts by local decisionmakers at the national forest or regional scale are best positioned to make decisions about inventoried roadless areas because they understand the unique ecological, economic, and social needs of their communities.” Note: Yes, this is being done for revisions under the 2012 planning rule. Ironically, the Roadless Rule Recission is itself a blanket one-size-fits-all mandate that the rule dispesl. I requested the DEIS disclose forests that have done plan revisions, those in the process, and those not started. Only those that have not started could be subject to the recission. Those completed or undergoing revisions have engaged in place-based, collaborative decision-making responsive to on-the-ground conditions. The DEIS fails to respond to my request.

I live in Missoula, Montana, and can see Lolo National Forest from my home. I previously lived in the PNW just outside Mount Baker-Snoqualmie National Forest and grew up skiing in the White Mountains and Green Mountains of New England. Hanging on the wall behind my computer as I write this comment is a map naming all four of our national land management systems and their governing agencies, with colorful pushpins marking the national forests, parks, grasslands, refuges, and monuments I’ve been fortunate enough to visit. I spend much of my time hiking, climbing, skiing, boating, camping, and simply enjoying public lands across the country. National forests are some of the places where I feel most at ease, where I feel lucky just to be alive, and roadless areas are where I can step outside of the world we’ve built and return to the home we’ve always belonged to. I also previously worked for the National Forest Foundation on conservation and forest-management issues. That experience taught me that forest management is complicated and that active, science-based management can be appropriate, including to address wildfire risk. It also taught me to be skeptical of broad changes that remove protections across millions of acres without first demonstrating that the existing framework is failing. I strongly urge the Forest Service to retain the 2001 Roadless Area Conservation Rule and select Alternative 1, the No Action alternative. I have also attached a longer version of this comment with additional context and questions for the Forest Service, including more detail on the ecological value of roadless areas, wildfire and roads, road maintenance and watersheds, timber harvest, existing environmental safeguards, the history of Forest Service management, and the cumulative effects of other changes to public-land protections. I hope the Forest Service will consider the attached document as part of my comment as well. The wildfire rationale does not appear sufficient to justify rescinding the entire rule. The 2001 rule already allows certain fuels treatments and road construction when necessary to protect public health and safety from an imminent catastrophic event. Prescribed and managed fire are not prohibited. The agency’s own analysis also raises questions about whether the rule is preventing necessary wildfire management. Roads themselves deserve more scrutiny. Humans caused approximately 84% of U.S. wildfires from 1992–2012, and human-caused fires were heavily concentrated near roads. The Forest Service already has more than 370,000 miles of roads and an estimated $10 billion maintenance backlog. New roads create permanent maintenance obligations and can damage watersheds, fish habitat, and water quality. This proposal also cannot be considered solely a wildfire measure. It removes restrictions on both road construction and timber harvest, and the agency recognizes that vegetation management and timber harvest can create the need for roads. I am not arguing that all timber harvest is inappropriate. I am asking the Forest Service to acknowledge that permanent road access changes what becomes economically and practically possible in a landscape over time. Other environmental safeguards are not equivalent to the Roadless Rule. For species such as grizzly bears, lynx, and bull trout, habitat loss and fragmentation are major threats. Once an intact watershed or wildlife corridor has been fragmented, project-level environmental review cannot simply put it back. The Forest Service’s own history should encourage humility. Management assumptions that once seemed unquestionably correct have changed as the agency learned from experience and from Indigenous knowledge. A road can be built in a season; meaningfully evaluating its ecological consequences can take decades. I ask the Forest Service to retain the Roadless Rule, identify specific cases where its existing exceptions have prevented necessary management, quantify the expected new roads and timber harvest in currently roadless areas, analyze the potential increase in human-caused wildfire ignitions, quantify long-term maintenance and watershed impacts, and explain how habitat and connectivity will be protected under the remaining safeguards. I’m not asking the Forest Service to stop managing forests or give up on wildfire mitigation. I am asking it to recognize that roadlessness itself has value, and that some losses cannot simply be reversed later. A forest can be cut in a few years. A centuries-old tree cannot be replaced on any meaningful timescale. An intact watershed cannot simply be put back together. When the consequences are potentially irreversible, the burden of proof should be high. If specific problems with the Roadless Rule exist, address those problems directly and use the narrowest effective tools. Please retain the 2001 Roadless Area Conservation Rule and select Alternative 1.

Repealing the roadless rule would be a disaster for my county, state and region both environmentally and economically. Our roadless areas in Northwest Montana are where the elk, deer and other big game live; these species can only survive and maintain healthy populations with large areas. Not only do these animals deserve to exist because they are God's creatures, they are also an important economic resource, as many people travel to this area to hunt them, and as a food source. My family and I hunt in our local roadless areas (Lolo National Forest, Thompson River) and are able to sustain ourselves, particularly in these increasingly expensive times, on game meat. The national forests surrounding us are already full of roads, which are poorly maintained as is. There is already a huge amount of access by road into our national forests; I do not see why further road development would be beneficial, and I can see many reasons why it would be harmful. Road development would also impact local streams and rivers by clogging them with debris and possibly impacting the routing of streams, which are necessary for the health of our local fisheries, which are again, important for their inherent value, the economic value they confer to our community through outdoor recreation and ecological stability. My husband, children and myself spend at least one day every week out in the forest up Thompson River (Lolo NF) fishing, hunting or hiking. Our forests are the most important source of carbon storage, and if they are allowed to be fractured further by roads, there is a greater likelihood that they will be further degraded, which would significantly negatively impact local rural towns, economies and our ecological health as a nation.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Elk and grouse still hold Stark Mountain because roads haven't reached it. I hunt those areas to put meat on my family's table. I fish the five major rivers around Missoula and many of the tributaries that fall within the roadless areas now at risk. This rule has kept those places intact, and I am filing this comment to oppose its rescission. Stark Mountain spans 12,601 acres in the Lolo National Forest. I have hunted there for years where elk and grouse thrive due to the lack of roads and pressure. The agency's own record confirms what I see on the ground: elk avoid areas near roads and select habitat away from them, and survival rates rose during a road closure and fell again when the gates were removed. Rescission would undo exactly the conditions that make Stark Mountain productive for wildlife and for my family. The same holds for Petty Mountain at 16,178 acres, Deep Creek at 7,669 acres, Garden Point at 6,322 acres, Reservation Divide at 16,908 acres, all in the Lolo National Forest and all places where elk benefit from roads being absent. The agency's DEIS also notes that upland birds need complex forest structure and that some show site fidelity that limits how far they can adapt when habitat changes. Losing these roadless areas, as I said, would negatively impact my family and our experience on public lands that can't be replicated elsewhere. I ask the agency to address specifically how the elk and upland bird populations in these named inventoried roadless areas will fare under rescission, given the agency's own findings about road avoidance and habitat fidelity. The proposal invokes wildfire and fuels management as a justification. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding directly contradicts the premise that new road access reduces fire risk. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it 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. I fish rivers and tributaries around Missoula that carry runoff from roadless watersheds. Logging and roadwork cause sedimentation that degrades water quality and fish habitat. Montana holds 235 inventoried roadless areas totaling 6,395,392 acres, and across the Northern region 1,287 municipal water intakes sit in watersheds containing affected roadless areas. The economic record does not make the case for rescission either. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The Forest Service already carries a $6.9 billion road maintenance backlog. The agency must reconcile this proposal with that record, and explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already in deficit. The proposal also argues that state-by-state approaches can replace the national rule. The agency's own prior record acknowledged: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency tried that state-specific replacement before and the Ninth Circuit found it deficient. The agency should explain, concretely, how this proposal avoids those same deficiencies and addresses its own prior finding that local decision-making can incrementally erode nationally significant roadless values. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. A federal court of appeals has already answered that question. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address that court's conclusion that the 2001 rule was within the authority Congress granted and did not create de facto wilderness, and state plainly what legal basis supports a contrary position now. Sincerely, Thomas Franklin Missoula, MT

Strongly Oppose Proposed Rescission of the 2001 Roadless Area Conservation Rule – Docket FS-2025-0001 To the U.S. Forest Service and U.S. Department of Agriculture: I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As a resident who cares deeply about our public lands, I rely on the integrity and protection of our inventoried roadless areas. I frequently visit or recreate near [Insert specific local roadless area or national forest, e.g., the Rattlesnake or Lolo National Forest areas] in [Insert your city/state]. Protecting these unfragmented landscapes is important to me because they safeguard critical wildlife habitats, maintain clean headwater watersheds, store vital carbon, and provide world-class backcountry recreation. Rescinding this rule would remove essential nationwide baselines, fragmenting management and opening millions of acres of wildlands to potential road building and commercial logging. I urge the U.S. Forest Service to abandon the proposed rescission and maintain full, durable protections for all designated inventoried roadless areas. Sincerely, Natalie Pertsovsky Missoula, Montana

To the U.S. Forest Service and U.S. Department of Agriculture: I am writing to express my strong opposition to the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). As an advocate for our nation's public lands, I rely on the integrity and protection of our inventoried roadless areas. The Roadless Rule has served as an effective, durable baseline that protects clean water quality, critical wildlife habitats, carbon storage, and high-value backcountry recreation across tens of millions of acres. Repealing this federal baseline and leaving decisions to local management will result in fragmented, uneven protections that cannot be undone once roads and logging cut through these intact forests. I frequently visit Lolo National Forest, Glacier National Park, Bob Marshall Wilderness, and value these lands because they protect local watersheds, provide crucial wildlife connectivity, and offer quiet backcountry recreation. There are few places in this world that are like these special lands in Montana and the mountain West, and they need protection. Once that protection is gone, there's no going back to the way things were. Roads stay for generations, as scars across the land. I urge the U.S. Forest Service to abandon the proposed rescission and maintain full protections for all designated inventoried roadless areas. Sincerely, Heather Lepp Missoula, Montana.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in Missoula, Montana and have been privileged to live/explore roadless areas in Northern Idaho, the Western Slope of Colorado and in Southern New Mexico. I many of my fondest memories with family and friends have been in roadless areas like fishing/floating in the Flathead NF/Bob Marshall Wilderness, hunting and berry picking in Lolo NF and mountain biking regularly in the Rattlesnake RA. Wild places like these are irreplaceable. From a financial standpoint, there is strong evidence showing there isn't a budget to maintain mind-boggling number of existing roads on public land. Further, I worry that that more roads lead to higher incidences of devastating human-started forrest fires. Please support Alternative 1 (no action alternative). Thank you for considering my comment. Cody Goss

Dear Secretary: I spend a lot of time in nature. Watching wildlife in roaded and unroaded country for a long time has shown me the rule is the variable that matters. The Rattlesnake wilderness is nearby where I live and provides habitat for a myriad flora and fauna. Roadless areas are important for migratory birds and animals. First time I ever felt a mountain lion watching me was in the Rattlesnake Wilderness. Access to roadless areas. Peace. I enjoy getting out to look for wildlife and watch the birds and rescinding this rule would take away peace and territory for many of God’s creatures. Regarding the Rattlesnake in the Lolo National Forest, Montana: Roadless forests provide undisturbed nesting, stopover, and wintering habitat for migratory birds protected under the Migratory Bird Treaty Act. Roads concentrate nest predators near edges. Predation by edge-following predators — Blue Jays, raccoons, snakes — is concentrated near roads, clearings, and forest edges. Distance to unpaved road was the strongest predictor of nest survival in a study of 463 nests across 17 songbird species. Nest predation, not parasitism, accounts for 75 to 100 percent of nest failures in most studies (DeGregorio et al. 2014; Akresh et al. 2024). — DeGregorio et al., 2014 (https://doi.org/10.1002/ece3.1049); Akresh et al., 2024 (https://doi.org/10.5751/JFO-00481-950212) Rescinding the Roadless Rule would open the Rattlesnake, Lolo 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. I think rolling back the 2001 Rule is just another bad idea by our current administration. Please don’t do it. The Department should close this proceeding by declining to rescind the 2001 Roadless Area Conservation Rule. With best wishes, CommentID: RLC-20261006-3D639I

I am writing concerning the proposal to rescind the Roadless Rule that is currently protecting 45 million acres in our National Forests. I am absolutely opposed to rescinding the Roadless Rule. I am 100% in favor of KEEPING the Roadless Rule in place. The roadless rule protects our old growth forests and sensitive ecosystems. It PREVENTS forest fires, and it PROTECTS our watersheds, which support wildlife and provide us with safe drinking water. I reside in Florida, and I love our Public lands. I have visited, camped and hiked in many of our national forests inlcuding Pisgah National Forest, The Great Smoky Mountains, Grand Targhee, Cibola National Forest, Lolo National Forest, Gulf Islands National Seashore, Bristlecone Pine Forest and more. I live part time in New Hampshire, where I enjoy hiking in the White Mountains. I am aware of the Granite State’s significance in establishing a National Forest service to begin with. Over 100 years ago, logging led to widespread wildfires and deforestation which in turn caused erosion and landslides which resulted in massive pollution in the Connecticut and Merrimack Rivers rendering them unnavigable. We must never go back to the BAD OLD DAYS. 

I also have a child who fights fires in the Owens Valley Conservation district in the Eastern Sierra Nevada Mountains. It is a Fallacy to state that rescinding the roadless rule helps with wildfire mitigation. The fact is, where there are roads, and where the canopy is thinned out due to logging wildfires increase and spread much more easily. Where the soil is disturbed by road building, and by logging, fast growing succession species come in. These are all too often invasive species that smother trees and provide more fuel for fires. I have personal experience managing infestations of oriental bittersweet on my 200 acre property in New Hampshire. This plant destabilizes soil running under existing native trees and shrubs. It grows rapidly because it can spread by seed, rooting, or cuttings. It quickly overtakes trees, blocking the light and killing them, creating more fuel for fires. The roadless rule preserves ecosystems and old growth forests which in turn provides far better protection against wildfire than roads and the accompanying logging ever could. Furthermore, protecting and preserving road free forests protects the watershed. This in turn protects not only the wildlife that depend on clean water, but the people, too. We cannot escape that we, too, depend on clean drinking water. This is why water management districts are so strict about what activities are permitted near reservoirs and the streams that feed them. More roads leads to more pollution due and more erosion. We must not allow this to happen. Finally, as someone who lived for several years in the Western Carolina mountains before moving to Florida, I urge you to protect the sensitive and diverse ecosystems that are in our National Forests. There are more species of flora and fauna in the Southern Appalachians than in the entire continent of Europe. Many exist there alone. Alpine, desert and wetland areas, too are fragile and must be protected. Once gone, they are gone for good. As I am a Christian, I believe we must respect and protect God’s creation, not destroy it for our own selfish and short sighted desires. Please, preserve the Roadless Rule as it is. DO NOT RESCIND IT.

To Whom It May Concern at the U.S. Forest Service: I am an educator, a guide and a natural historian. Guiding and teaching outdoors for over a decade has shown me that the 2001 Rule has aged into the agency's regulatory architecture in ways the proposed rescission has not adequately accounted for. Wild spaces are important to the animals and plant species that live there, not just to the humans that use resources from those areas. Further, the more-than-human world depends on roadless areas for safety and survival. Regarding the Rattlesnake in the Lolo National Forest, Montana: Approximately 363 acres (~12.6%) of the Rattlesnake IRA in Lolo National Forest is mapped as Rocky Mountain Dry Subalpine Spruce-Fir Forest (Rocky Mountain Subalpine Dry-Mesic Spruce-Fir Forest and Woodland) (GNR), the ecosystem NatureServe associates with Whitebark Pine (Pinus albicaulis, G3). The species is documented present in the area. Road construction reduces both the extent and quality of this habitat. Construction of roads in the Rattlesnake IRA converts intact Rocky Mountain Dry Subalpine Spruce-Fir Forest (Rocky Mountain Subalpine Dry-Mesic Spruce-Fir Forest and Woodland) to road surface and disturbed margins, reducing both the total acreage (~363 acres) and the functional connectivity of the remaining habitat for Whitebark Pine (Pinus albicaulis). Fragmented ecosystem patches support fewer individuals and reduce population viability for this G3-ranked species. The DEIS must evaluate road construction impacts in the Rattlesnake IRA on both Whitebark Pine (Pinus albicaulis, G3) and Rocky Mountain Dry Subalpine Spruce-Fir Forest (Rocky Mountain Subalpine Dry-Mesic Spruce-Fir Forest and Woodland) (GNR, 12.6%, ~363 acres) as an integrated species-habitat impact. Analyzing the ecosystem without its documented imperiled species, or the species without its mapped habitat, produces an incomplete and legally inadequate analysis. "Within 1 km of roads, forests show 18.6% lower forest cover, 2.7 m shorter canopy height, 52.2 gC m-2 yr-1 reduced net primary productivity, and 23.0 patches per km2 higher fragmentation compared to reference areas. Impacts extend up to 5 km with a clear distance decay effect, totaling 4.26 million km2 of forest loss—equivalent to 10.7% of the 2020 global forest extent." — Nature Communications, 2026 “Within 1 km of roads, forests show 18.6% lower forest cover, 2.7 m shorter canopy height, 52.2 gC m-2 yr-1 reduced net primary productivity, and 23.0 patches per km2 higher fragmentation compared to reference areas. Impacts extend up to 5 km with a clear distance decay effect, totaling 4.26 million km2 of forest loss—equivalent to 10.7% of the 2020 global forest extent. — Nature Communications, 2026 (https://doi.org/10.1038/s41467-026-69150-4)” If the roadless rule was rescinded, the backcountry areas where I take my students backpacking would no longer exist; bulldozed roadbeds would end those trips. If the roadless rule was rescinded, the species we learn about on the courses I teach -- Whitebark Pine trees, native Bull Trout, Grizzly Bears, Beavers -- would no longer have a good chance of survival. For the foregoing reasons, I urge the Department to retain the 2001 Roadless Area Conservation Rule. Keep the protections, please. Warm regards, CommentID: RLC-20261006-QUB57W

Dear USDA Leadership: As an outdoor enthusiast, I know that some things on public land can be restored and some things can't. Road impacts fall in the second category. This land is what restores my connection to my community, our sources for clean drinking water, and rejuvenation to continue good work with my neighbors. Just last week, I was able to spend a night in the Rattlesnake mid-week. Close enough to town but remote enough to make me feel like I traveled far away yet was still back at work the next morning. Our town draws our drinking water off that unroaded watershed. Regarding the Rattlesnake in the Lolo National Forest, Montana: Forest plan consistency, multiple-use direction, and how proposed management would alter the roadless character of inventoried areas. Rescinding the Roadless Rule would open the Rattlesnake, Lolo 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. We lose traditional values of the land with the loss of this rule. The Department is urged to terminate this rulemaking without rescinding the Roadless Area Conservation Rule. With best wishes, CommentID: RLC-20261006-IBIV3X

I have visited official roadless areas across the Western United States - from Montana to Wyoming to Alaska to Utah. I have spent months exploring these places and have backpacked with my daughter for over twenty years. Her first backpack trip in Montana - when she was less than one, was of course in a designated roadless area. I have also instructed hundreds of students in designated roadless areas. They have been a key feature of my life's work for four decades. Gutting the Roadless rule is unwarranted, harmful, dangerous, and expensive. I and millions others will no doubt be harmed. New research confirms that we have more wildfires where there are more roads. This is dangerous to those of us who live in the city (in my case, Missoula MT) and also live close to a roadless area. I live close to and frequent often the Rattlesnake Roadless Area in the Lolo National Forest. Roads would hasten its demise and lessen our enjoyment. We know that Roadless Areas are needed so myriad birds and wildlife can exist. We also know that these lands buffer temperature extremes and provide intact refugia where wildlife and plant species can shift in response to a warming climate. Our climate is already warming and rescinding this rule will only hasten ecosystem fragmentation and degradation. I also work professionally to reduce the impacts of wildfire smoke and emissions, and it has come to my attention that the Comparative Wildfire-Emissions Finding rests on an analysis the DEIS says was not performed. The Draft EIS makes an affirmative comparative finding about wildfire emissions and states, three pages earlier, that the analysis supporting it was not performed (see the Air section of Chapter 3). This is just one example of the troubling Roadless Rule draft EIS that is unsupported by credible science. It's simply sloppy, shady science that this proposed ruling tries to stand up. We're not buying it. Millions of informed Americans have spoken: Do not rescind the roadless rule. Thank you for your consideration. Amy Cilimburg Missoula, MT

To the Department of Agriculture: I am a recent graduate from the University of Montana who has recreated in the Rattlesnake wilderness since I arrived here for college. The Rattlesnake is a place of peace, community, exploration, clean water, and clean air. Public, connected lands have mattered to my family for generations as I come from a long line of recreationists, hunters, anglers, and outdoorspeople. The Roadless Rule keeps these places intact and I want my children to see them that way. Please defend the Roadless Rule. My friends and I would walk in the Rattlesnake after long, stressful days or to celebrate birthdays in the outdoors! This place is very special to us. We want to see this area prosper, not die. If this rule is rescinded, I lose peace, connection to the natural world, and a legacy of enjoying intact public lands. I lose clean air, clean water, and space in which to get away from everyday life as I knew it before. Nature is inextricably linked to human wellbeing and fracturing it hurts us, too. Regarding the Rattlesnake in the Lolo National Forest, Montana: Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Intact forests provide ecosystem services that fragmented ones cannot. Primary forests with the least disturbance history have the highest carbon storage, the highest ecosystem-process levels, greater stability and recovery, and the lowest risk of loss. Connectivity, biodiversity, and microclimate buffering combine to give intact forests greater adaptive capacity in a changing climate (Rogers et al. 2022). — Rogers et al., 2022 (https://doi.org/10.3389/ffgc.2022.929281) Rescinding the Roadless Rule would open the Rattlesnake, Lolo 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. Roadless areas mean the future health of our planet. You play a role in that future. Please consider your legacy when making this decision. Young people today and children not yet born will wonder why you didn't defend the lands that the American People prize so greatly; our whole, intact ecosystems. They will wonder why they choke on poor air and why their water is no longer safe to drink. They will wonder where their parents recreated, since the stories of whole ecosystems will no longer be applicable if the Roadless Rule is lost. Defending public lands is a service to the country and to the world. Please take that service seriously. Roadless means roadless. Honor that.

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

Re: Special Areas; Roadless Area Conservation, Proposed Rule (RIN 0596-AD66) [Docket No. FS-2025-0001] To the U.S. Department of Agriculture and U.S. Forest Service: On behalf of YAMA Mountain Gear LLC, I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. YAMA Mountain Gear is a small, independent company that designs and builds lightweight shelters for backpackers. We are based in Bonner, Montana, surrounded by the Lolo National Forest. Much of the backcountry where we test our gear and spend our own time outdoors, including places like the Great Burn, is roadless country. Our customers carry our shelters into National Forests across the country, and the undeveloped landscapes they seek out are, in large part, the Inventoried Roadless Areas this rule protects. The Roadless Rule is a modest and effective policy. It applies to specific, mapped areas of National Forest that were inventoried as still roadless. Within them, it prohibits new road construction and commercial timber harvest, which in practice also keeps out most new mining. It does this without designating Wilderness, closing existing roads or trails, or restricting hiking, hunting, fishing, or grazing. It simply keeps new roads and timber sales out of the last large, intact blocks of National Forest land. Those areas matter far beyond their boundaries. Inventoried Roadless Areas provide habitat and migration corridors for wide-ranging wildlife, protect water quality at the headwaters of streams and rivers that downstream communities depend on, and preserve the backcountry recreation experiences that draw people to public lands. They are also inexpensive to manage. The Forest Service already faces a substantial backlog of maintenance on its existing road system; adding new roads in roadless areas would add new long-term costs to an agency that cannot keep up with the roads it has. These lands are also an economic asset. They contribute to a national outdoor recreation economy of roughly $1.3 trillion, and to the rural communities, guides, outfitters, and small manufacturers like us that depend on it. Opening roughly 45 million acres still covered by the national rule to new roads, logging, and mining would trade durable, long-term value for short-term extraction. We recognize that wildfire is the central justification offered for this proposal, and we take that concern seriously. Reducing fire risk to communities is important work, and we would welcome future rulemaking that improves the rule's ability to support fuels reduction and prescribed fire where it is genuinely needed. But the evidence on roads and fire cuts both ways: most wildfires are human-caused and tend to start near roads, and new road networks create new ignition points. A targeted, science-based approach to fire management in roadless areas deserves careful consideration. A wholesale rescission is not that approach. That is the core of our objection. The choice presented here is not reform; it is removal. Rescinding the rule entirely would open tens of millions of acres to road building, logging, and mining without any national plan to protect the habitat, water, and recreational values that depend on these areas staying roadless. Shifting those decisions to individual forest plans would replace a consistent national standard with a patchwork that local units, already stretched thin, would struggle to administer. When the Roadless Rule was adopted twenty-five years ago, more than 1.6 million public comments helped shape it, reflecting broad public support for protecting these lands. A decision to undo it deserves comparable public engagement. A 45-day comment period with no public hearings is not sufficient for a proposal affecting roughly 45 million acres across dozens of states. At a minimum, we ask the Department to extend the comment period to 120 days, hold in-person public meetings in affected regions, and complete full consultation with tribal nations before proceeding. We respectfully urge the Department to withdraw the proposed rescission and retain the 2001 Roadless Rule. If changes are warranted, particularly regarding wildfire mitigation, we ask that the agency pursue targeted improvements, developed with the kind of public engagement described above, rather than eliminating protections for some of the most valuable public lands in the country. Thank you for the opportunity to comment. Sincerely, Gen Shimizu Founder/Member YAMA Mountain Gear LLC Bonner, MT

Dear Secretary Rollins: The experience of traveling through genuinely roadless country has shown me that the 2001 Rule codified something the public had long sought but lacked the regulatory mechanism to secure — and the Department's proposed rescission would dismantle that mechanism without commensurate justification in the record. I live on Rattlesnake creek in Missoulla. I enjoy hiking up into the wilderness area every summer. I would hate to see logging or any road building in this area that so many of us Missoulians use. I would loose the ability to experience wilderness so close to home. Regarding the Rattlesnake in the Lolo National Forest, Montana: In the Rattlesnake Inventoried Roadless Area, Lolo National Forest, Whitebark Pine (Pinus albicaulis, G3, T) faces documented threat from 5.3 - Logging & wood harvesting at Slight or 1-10% pop. decline severity across Small (1-10%) scope. Road networks serve as vectors for the secondary impacts classified under 5.3 - Logging & wood harvesting: they open previously inaccessible terrain to resource extraction, facilitate introduction of invasive species, and concentrate human disturbance along corridors through Whitebark Pine habitat. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Forest Service Chief Tom Schultz testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. 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 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. Finally, these figures serve the final rule as well as the environmental impact statement. The proposal reverses findings the Department made in 2001 about the effect of roadless protections on management, and this FACTS baseline is the factual finding on which that reversal rests. Where a new position rests on factual findings that contradict those underlying the prior policy, the explanation must be more detailed, not less. FCC v. Fox Television Stations, 556 U.S. 502, 515–16 (2009); Encino Motorcars, LLC v. Navarro, 579 U.S. 211, 221–22 (2016). I request that the final rule preamble address the corrected figures and the disaggregated series directly, and not by cross-reference to the FEIS response-to-comments appendix. Rescission serves the fewest. The Rule serves the most. Keep the Rule. Warm regards, Daniel Volkmann

Dear Secretary Rollins and Chief Schultz: In my decades of pursuing game and wild fish on national forest lands, I have observed that the qualitative difference between roaded and roadless terrain is not a matter of preference but of habitat function, and the 2001 Rule preserves that function at the regulatory level. I spent many hundreds of days hiking , hunting and fishing the Cube Iron-Silcox Roadless areas as well as many other roadless area in Montana, Idaho, Colorado and New Mexico. As a fisheries technician and fisheries biologist I have dedicated my life and have spent an equal amount of time within these landscapes working to study and conserve the species that have lived in them since time immemorial. I have many memories of these roadless wild landscapes that I will never forget. They support critical habitats for big game, small game and many hundreds non-game terrestrial species. Roadless lands supports most of the quality aquatic habitat that remains for sensitive aquatic species such as bull trout, westslope cutthroat trout and rocky tailed frogs; among any other native species. Don’t let this greedy corrupt admission overturn the roadless rule to make a few wealth sycophants even richer. Hand off! We as the public will lose the solitude, immense beauty, critical wild and fish habitat and the ecosystem services these roadless landscapes provide. Once the roads are built the land is not the same…and doing it under the guise of fire suppression is cheap and fake joke developed by those well connected-wealthy opportunists that want to profit off our public land and those that support the corrupt criminals that current “lead” our government. Regarding the Cube Iron - Silcox in the Lolo National Forest, Montana: Suckley's Cuckoo Bumble Bee (Bombus suckleyi), ranked G2 by NatureServe and federally listed (PE), is present in the Cube Iron - Silcox IRA, Lolo National Forest, where it confronts 7.3 - Other ecosystem modifications at Extreme or 71-100% pop. decline severity across Restricted (11-30%) scope. 7.3 - Other ecosystem modifications requires infrastructure access to operate at scale. Roads are the prerequisite — they deliver the machinery, chemical inputs, and repeated human intrusion that transform this threat from latent to active in areas like Cube Iron - Silcox. A programmatic analysis is insufficient. The DEIS must evaluate 7.3 - Other ecosystem modifications impacts to Suckley's Cuckoo Bumble Bee (Bombus suckleyi, G2) at the scale of the Cube Iron - Silcox Inventoried Roadless Area, Lolo National Forest, with specificity adequate to inform the decision. "From a sample of 463 nests of 17 songbird species, we evaluated how landscape features (distance to forest edge, unpaved roads, and power lines) influenced daily nest survival. For all nesting species combined, distance to unpaved road was the model that most influenced daily nest survival. Numerous nest predators, including brown-headed cowbirds, mammalian mesopredators, and snakes, have been shown to preferentially occupy habitat edge over interior. Rat snakes were frequently associated with road edges, indicating that not all edges are functionally similar." — Ecology and Evolution (PMC), 2014 Roads change forests in ways that can't be reversed on a human timescale. The rule that has prevented that from happening in these areas should stay in place. All the best, Jason CommentID: RLC-20260926-T1Y8UH

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Rattlesnake Wilderness is where I taught my daughter to fish, mountain bike, and backpack. We go there to take in the seasons, watch the wildlife, and breathe the fresh mountain air. That wilderness sits inside the Lolo National Forest, alongside roadless areas like Stark Mountain and Lolo Creek, and it is the kind of landscape this rule has protected for over two decades. I am submitting this comment in opposition to Docket FS-2025-0001. I submitted a comment during the 2025 attempt to rescind the rule. I was not shocked to receive no response from the Department, but it still frustrates me that the government doesn't appear to care what a resounding majority of Americans want. The agency solicited reliance interests and then did nothing visible with them. The agency's own framing invites this: "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 one such interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. On the economics: the record states that "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 is proposing to dismantle a rule that protects millions of acres on the basis of contributions this modest. More striking, 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, with a net present value spanning -$92 million to +$199 million. That range does not establish a net benefit, and it does not account for a road maintenance backlog already sitting at $6.9 billion. I ask that the agency reconcile the proposal with that analysis and explain how an action that cannot demonstrate net economic benefit justifies expanding the very road system that backlog represents. The small-business certification deserves the same scrutiny. "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 supporting analysis reaches its no-impact conclusion by spreading losses across the national average firm rather than examining the outfitters and guides who actually hold permits in the affected roadless areas, and it concedes that some of those firms may lose those receipts. Montana alone holds 235 inventoried roadless areas totaling 6,395,392 acres, and the Northern region contains 1,287 municipal water intakes in watersheds with affected roadless areas. The small businesses and communities downstream from places like Lolo Creek and Stark Mountain are not national averages. The agency should withdraw the certification and assess the impact on the specific small entities operating in and around these areas. When I was a kid, fire season was not part of everyday vernacular. Now it is guaranteed every summer. Out here in Montana, we are subjected to weeks if not months of unhealthy air every summer, and it is getting worse. The agency's own data make the connection to roads plain: "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis concedes that new road access could increase the number and frequency of wildfires, yet the proposal is advanced in part on wildfire-reduction grounds. How does the agency square those two positions? I expect a direct answer: the agency must quantify the expected increase in human-caused ignitions from new road access and weigh that figure against the claimed reduction in wildfire hazard before this proposal advances any further. Thank you for your time, Kerry Gallagher Missoula, Montana

My name is Rachel and I am a fifth generation Montanan. I absolutely love this state. I feel that it is a privilege to be called a Montana to my core. I care so deeply about the pristine roadless parts of the state and have so much concern for what removal of this rule will mean to the place that I love. I am a mom of two boys and want them to experience the Missouri breaks, the Bob Marshall wilderness, Lolo national Forest and Flathead national Forest, to name a few, as I have done in my time on this planet. Building roads in these and other untouched areas will be a detriment to the environment. It would be a detriment to different plant and animal species, to the untouched areas that can only be accessed by foot, and will expose these places of natural beauty to resource excavation and practices that will harm the environment, harm the land, harm Montanans for generations to come. Please protect the roadless rule and save my state for my kids and many more to come in the future. Thank you!

To whom it may concern: I spend time nearly daily in the Lolo National Forest, as well as so many others around the West. There are many inventoried roadless areas that are incredibly important to me because I harvest deer to feed my family there, hike to keep my body healthy there, and find solace to keep my mind strong there. I support retaining durable conservation measures while providing carefully defined flexibility for forest restoration, community safeguarding, fish and wildlife habitat improvement, and necessary fire management. The Forest Service does not need to choose between healthy, resilient forests and conserving the intact backcountry. Please support Alternative 1 – No Action. This alternative keeps the existing 2001 Roadless Area Conservation Rule in place. Thank you sincerely for reviewing all the public comments Americans are sharing on this topic and applying the vast support for maintaining existing roadless areas in your decision-making. Hannah Nikonow