Read the comments.

Continued: 4. Fire is a part of the ecosystem. To the extent that the rationale is reducing fire, the rationale is wrong, as other commenters have pointed out and as the rationale points out, that more roads lead to more fire activity. But also the entire proposal is misplaced — because the most effective way to address fires of increasing intensity is to address climate change. That is the real national priority that needs to be addressed that the government is completely failing to address. Roads in forests are not a recognized wild-land fire management policy, as other commenters have pointed out. *** Put simply, the repeal of the Roadless Rule is a step backwards in public lands management. It effectively takes public lands out of the hands of the people they are set aside for — the American public — and hands them to special interests who are willing to pay for them. This is not the mandate that the USFS has been given by Congress. The mandate is the manage these lands for multiple uses. Creating new roads in forests prioritizes only one use, timber harvesting, over all others. *** My experience in this comment is drawn from recreating at the following USFS properties: Little Missouri National Grassland; Buffalo Gap National Grassland; BigHorn National Forest; Chequamegon-Nicolet National Forest; Hiawatha National Forest; Ottawa National Forest; Huron-Manistee National Forest; Superior National Forest; Chippewa National Forest; Shoshone National Forest; Custer-Gallatin National Forest; Flathead National Forest; Bridger-Teton National Forest; Caribou-Targhee National Forest; Gifford Pinchot National Forest; Olympic National Forest; Okanogan-Wenatchee National Forest; Mount Baker-Snoqualmie National Forest; Colville National Forest; Medicine Bow-Routt National Forest; Arapaho National Forest; White River National Forest; Black Hills National Forest; Thunder Basin National Grassland; Unit-Wasatch-Cache National Forest; Sierra National Forest; Stanislaus National Forest; Lincoln National Forest; and Shawnee National Forest. My major takeaway from all these experiences is that these Forests already have more roads than most people could explore in a lifetime. There is quite simply no practical or logistical need, from a recreational perspective, for more under the rationales that the USFS has proposed in this rule change.

As a Wyoming resident with access to parge areas of national forest nearby, I see the rescinding of the roadless rule as destructive to those areas of forest as well as needlessly costly to taxpayers. The Snowy Range on the Medicine Bow National Forest has seen several large wildfires in the last decade, and most of those were concentrated on the southern half of the range, where there is already extensive road development. Since most of these fires were determined to be human caused, it contradicts the argument put forth that additional road development helps prevent wildfires. Most of the fires occurring in Wyoming are human caused, and most of those occur in areas with existing road networks, thereby establishing a strong correlation between roads and fires. Additionally, the Medicine Bow-Routt National Forest has a large road maintenance crew compared to other national forests in the surrounding area. They do good work, but are underfunded and understaffed just like every other Forest Service maintenance crew in the region. Many of the roads on the Medicine Bow-Routt National Forest have fallen into disrepair due to years of neglect. Repealing the roadless rule will simply add to an ever-growing backlog of road maintenance that the Forest Service is already unequipped to maintain. We will in effect be sacrificing conditions even more on existing roads in order to build new ones that will promptly go unmaintained.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Living near the Routt National Forest when the original roadless rule was passed shaped how I think about these lands. I go to the forest to reset, to forage, and to share with my kids. I used to ride trails near Steamboat. I go out looking for moose, bears, sandhill cranes, owls, you name it. I love to photograph the historic buildings out on the forest. Black Mountain, in the Medicine Bow-Routt National Forest, is a place I know to hold mushrooms and other resources that deserve protection. This comment opposes the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). The agency's own record undermines its wildfire rationale. The DEIS 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." I have been evacuated twice for fires. Roads would not improve our response; these fires are too big, too quickly. 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 DEIS Table 21, which the agency's own analysis shows reflects far higher fire density on roaded land than inside the affected roadless areas. More roads also threaten the wildlife I go out looking for. The DEIS notes that moose are drawn to road corridors for road salt, which increases human-moose interactions and conflict. The DEIS separately quotes the federal grizzly recovery plan on bears: increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. Beyond conflicts with individual animals, the agency's own Tribal record credits the rule's protection with the recovery of deer and moose populations by preserving old-growth winter shelter. I also know from my own time out there that more roads mean more looting of the historic sites and buildings I photograph. The agency needs to explain how opening the road system addresses any of these documented harms rather than compounding them. The economics do not support 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 Forest Service cannot manage the roads it already has as system roads; I ask that the agency reconcile the proposal with its own Cost Benefit Analysis, which 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, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog can be justified when the agency's own analysis cannot establish a net benefit. The proposal also misrepresents how restrictive the current rule actually is. The rule as written already states it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The original purpose of the Forest Service was to protect resources, and the existing exceptions already cover the situations the agency claims the rule prevents. Which specific burdens are not already addressed by those exceptions, and why has the agency not quantified them? Finally, the regulatory flexibility certification does not hold up. "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." Spreading an annual expenditure loss across every small firm nationally rather than assessing the outfitters and guides actually holding permits in the affected areas is not an honest analysis. The agency should withdraw that certification and assess impact on the small entities actually operating in these roadless areas. The agency has to answer why this rescission is needed, when so much work was done to put the original roadless rule in place. Sincerely, R. Morris Colorado

To whom it may concern: I am writing to comment on the proposed repeal of the 2001 Roadless Rule. I strongly oppose the proposal to fully or partially rescind the 2001 Roadless Rule. I understand that public comments are supposed to clearly outline negative environmental impacts by copiously citing studies and data. I am not a scientist, and am clearly aware you will receive stronger, more persuasive letters from a scientific and policy driven standpoint than what I could write. I am simply a humble hiker who relies on wild places to create joy and meaning in my own life. Human beings need roadless territory. Many will write about the destruction of critical ecosystems, and forest habitat, areas of which endangered species rely heavily upon. But we are also talking about our own human habitat. Humans need wild spaces. As Edward Abbey writes in Desert Solitaire: “Wilderness is not a luxury but a necessity of the human spirit, and as vital to our lives as water and good bread.” Roadless areas provide us with true, uninterrupted, undisturbed wilderness, where we can throw off the confines of society and let our souls roam wild. We need these spaces to challenge ourselves, to force ourselves to be brave, deep in the wilderness, with no chance of giving up, or someone coming to get us. Wilderness areas help shape us into stronger, more resilient human beings. Roadless areas leave us stranded and force us to persevere. This summer I hiked through roadless areas of the Bridger-Teton National Forest and Medicine Bow-Routt National Forest. I had no choice but to face my fears, my boredom, my struggles and found healing and renewed strength through the solitude. I understand this may sound wish - washy to those who want to profit from resource extraction, yet we as humans need restoration and connection with nature to create meaningful, fulfilling lives. People’s desire and need for wilderness helps to support a $1.3 trillion dollar a year outdoor industry. Preserving roadless wilderness areas is sustainably profitable. I find it extremely disheartening that I find myself continuously writing of my opposition to the USDA and Forests Service. Every time this proposal is up for consideration, the American public has vehemently stood against it. We deeply value our sacred wild places and want to preserve our forests. When will you choose to listen to the will of the people and stop being swayed by corrupt politicians and corporate interests? The American people don’t want to repeal the roadless rule. Every time this comes up for public comment, the American people give the same answer: No. Thank you for your time and consideration, Sincerely, Ashley Makela New Hampshire

My trails are at St. Mary's Lake, the Happy Jack area, and Turtle Rock. Lake Marie is where I paddle. The birds, fish, deer, elk, and lynx I watch out there are part of why I go. They're quiet areas which allow me to connect with nature and gain new perspectives. This proposed rescission of the 2001 Roadless Rule threatens everything that makes those places worth protecting, and I oppose it. The agency estimates, in the Economic Benefits from Recreation in Roadless Area Forests section, that "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally." That figure is measured against roadless recreation benefits of upwards of $1.5 billion, and the same section acknowledges that the magnitude of losses is unknown. I hike, paddle, photograph the trees and mountains, and watch wildlife in the Medicine Bow-Routt National Forest. Roads and changed recreation settings do not disappear after one year; they accumulate and persist for decades. The agency must estimate cumulative recreation losses over 20 years as roads and settings change, compare those figures against projected timber revenue, and explain that analysis clearly. The forest health rationale in the notice also does not hold together. The agency states in its Rationale for the Proposed Rule that "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 has contributed to challenges in addressing forest health concerns." Yet the document also cites research finding the rule did not meaningfully constrain fuel treatments as a share of forested land, and it notes that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. The agency should reconcile these findings before using forest health as a justification for rescission. I live about an hour from the Medicine Bow area and 20 minutes from Happy Jack. Both are already busy with locals and visitors. Building more roads will not help people engage better with the land. It will put more pressure on areas that are already stretched. The agency should explain how expanded infrastructure improves the visitor experience rather than degrades it for those who already use these places. The timber math also matters here. The document states that "approximately 11-16 percent is old-growth forest, 54-63 percent is mature forest, and 26-31 percent is young forest" in the operable areas most likely to be logged under the proposed action, as shown in the Implications for Forest Vegetation, Health, and Carbon section. Old and mature stands make up the large majority of what would be opened. The document identifies no old-growth-specific safeguards beyond general land management plan compliance. The agency must separately analyze and disclose what protections, if any, would apply before harvest in these largely old and mature stands is authorized. The Laramie aquifer and the rivers it feeds downstream depend on the integrity of these forests. Water is already a precious resource and needs to be left alone for our future. I am also deeply skeptical of the cost side of this decision. The current infrastructure in our national forests already needs repair, and DOGE cuts have forced needed maintenance and improvement projects to be postponed indefinitely. We should repair what we have before expanding roads further. The current cost estimates alone should be reason enough to pause. Nature has power when it is left alone, and species that cannot advocate for themselves depend on decisions like this one being made carefully.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Snowy Range in Wyoming is what prompted this comment. I hike and camp in the 29,660 acres of inventoried roadless area in the Medicine Bow-Routt National Forest because the particular combination of the smell of spruce and fir trees, the sound of woodpeckers, warblers, and chickadees, and the sight of nodding mountain wildflowers is not available anywhere closer to the grind of civilization. I oppose the rescission of the 2001 Roadless Area Conservation Rule as proposed in Docket FS-2025-0001. Regarding the birds, the agency's own record is direct about what roads do to them. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31% of species avoiding the noise entirely. Wyoming holds 116 inventoried roadless areas totaling 3,243,958 acres. Opening those areas to road construction is not a neutral administrative act; the agency's own science says it degrades the habitat and the soundscape that make birds present and audible in the first place. I ask the agency to explain (specifically and with reference to those cited findings) how the proposal is consistent with the bird abundance and species-avoidance data in its own DEIS. The proposal justifies rescission partly on wildfire and fuels management grounds. 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 sentence is in the agency's draft environmental impact statement, supporting the rule the agency now proposes to rescind. The agency should explain why the proposal departs from this finding, and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. On economics, 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 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 ranging from -$92 million to +$199 million. The agency's own numbers cannot establish a net benefit. It has not explained how expanding a road system already carrying a $6.9 billion maintenance backlog is justified when the economic case for doing so is this uncertain. The agency must reconcile the proposal with its own Cost Benefit Analysis and answer that question plainly. The permitting and administrative-burden rationale fares no better against the rule's actual text. The rule as written states: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency has not identified which specific operational needs fall outside those existing exceptions. It should identify them by name, quantify the burdens they represent, and explain why the exceptions for public health and safety, existing mineral leases, and community wildfire protection do not already cover the cases it is concerned about. Finally, the regulatory flexibility analysis certifies no significant impact on small entities. The DEIS identifies outfitters, guides, and tour operators as affected parties, and the Cost-Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The agency reached its no-impact conclusion by spreading a $9 million annual expenditure loss across every small firm in the sector nationally, rather than examining the outfitters and guides actually holding permits in the affected areas, and it concedes that some firms may lose these receipts. 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 should be withdrawn, and the impact should be assessed on the small businesses actually operating in the potentially affected roadless areas, not the national average firm. Sincerely, Rachel Hayes Laramie, WY

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Bighorn and Snowy ranges are where I go to escape, to camp in the front country, backcountry, or simply boondock somewhere remote. I return to these forests for unparalleled solitude, natural beauty, and an abundance of wildlife, including moose, elk, mustelids, and birds of prey. I photograph charismatic mammals large and small and watch raptors and woodpeckers in the forest. At Libby Flats in the Medicine Bow-Routt National Forest, I have fond memories with family taking in the views and the wildlife, from elk to marmots. I want to see this place protected for others in the future. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. Our public land should be managed for the benefit of the American public and their children, not for private for-profit interests. Access to solitude, wildness, clean water, quiet, and outdoor recreation is part of our heritage as Americans. Rescission of the rule puts all of that at risk across the roadless areas I named in this comment, including Sibley Lake and Devils Canyon in the Bighorn National Forest, Bridger Peak and Libby Flats in the Medicine Bow-Routt National Forest, and Beaver Park in the Black Hills National Forest in South Dakota. The agency's own record contradicts the wildfire justification for this rescission. The DEIS 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." If that finding is in the agency's own draft environmental impact statement, the proposal to open these areas to road building requires the agency to explain why it departs from those findings. On the question of permitting burden, the agency's own description of the existing rule notes that it already carries exceptions: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Before rescinding a rule that protects roadless areas across millions of acres, the agency must identify which specific burdens are not already addressed by those existing exceptions, including the ones for public health and safety, existing mineral leases, and community wildfire protection, and it must quantify those burdens with actual data. I rely on the watershed shaped and safeguarded by Black Hills National Forest. South Dakota holds 8 inventoried roadless areas totaling 79,597 acres, with 325 municipal water intakes across the Rocky Mountain region sitting in watersheds containing affected roadless areas. We need fresh, clean water in the west, not more roads. The agency has documented that roads and their facilities can produce a substantial share of the sediment from a timber sale; opening roadless areas to new construction is unreasonable. The elk I look for in these forests are directly addressed by the agency's own citations, and the record falls short. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. That finding appears and then stops. No projection of population-level effects on elk or other big game across the affected environment follows anywhere in the document. The agency must project those effects and their consequences for big game populations and hunter opportunity before finalizing any rescission. The same gap appears on habitat fragmentation. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The moose, elk, and birds of prey that draw me to these forests depend on intact, connected habitat. Citing that range without applying it to the 40.1 million acres of potentially affected environment is not analysis; it is notation. The agency must apply the cited fragmentation range to the full affected acreage and show what the record actually predicts for the wildlife those acres support. The agency built Alternative 3 in direct response to commenters who asked it to protect big game habitat, fisheries, and wildlife connectivity, and then selected the alternative that protects none of it. That choice requires a reasoned explanation. What does the record show drove the agency away from the alternative its own process generated in response to public concern about wildlife? That question deserves a direct answer before this proceeding closes. Sincerely, Elizabeth L Custer, South Dakota

Comments on the 2001 Roadless Area Conservation Rule Docket number FS-2025-001 Executive Summary Mitch Keiler, Environmental Programs Manager and former natural resources professional, submitted this formal comment strongly urging the U.S. Forest Service to adopt the No-Action Alternative and retain the 2001 Roadless Area Conservation Rule (Docket number FS-2025-0001). Drawing from a 40-year career in public land stewardship, Keiler argues that completely rescinding the national safeguards will trigger severe, irreversible degradation across distinct American ecosystems. The letter attached as a separate file outlines critical, region-specific ecological and economic risks associated with the proposed rule rescission: •Medicine Bow-Routt National Forest (CO): Road construction and commercial logging will cause severe forest fragmentation, disrupting vital migration corridors for big game (elk, mule deer, bighorn sheep). Furthermore, USFS data indicates timber roads will double the presence of invasive plants in subalpine zones, threatening Colorado's multi-billion-dollar outdoor recreation economy. •Monongahela National Forest (WV): Developing steep, highly erodible Appalachian slopes will cause massive sedimentation in crucial headwater streams that feed the Ohio and Potomac River basins. This degradation will escalate municipal water treatment costs for millions of residents and decimate native brook trout habitats. •Washington State: Opening remote, temperate rainforests and old-growth stands to road building will compromise powerful carbon sinks, undermining federal climate mandates. Additionally, proximity to roads is shown to quadruple wildfire ignition density, creating an unacceptable risk to local communities. •Maine: Removing protections will fragment the last remaining intact blocks of northern hardwood and boreal transition forests. This isolation threatens vulnerable interior forest species, including the Canada lynx and pine marten. Financial & Legal Conclusion: The letter concludes by pointing out that modest projected timber revenues do not offset the staggering capital costs of new road construction, especially given the agency's existing $7 billion road maintenance backlog. Keiler asserts that rescinding the rule shortchanges long-term ecological stability, clean water security, and tribal treaty rights for deficit-ridden, short-term extractive gains. Enclosure: Letter for the Record

As an outdoorsman, public-land user, taxpayer, and Wyomingite, I am wholeheartedly opposed to rescinding the Roadless Rule. I urge the Forest Service to choose the No Action alternative outlined in the Draft Environmental Impact Statement (DEIS). In Wyoming, the Roadless Rule protects local communities’ drinking water supply from contamination, preserves critical wildlife habitat and migration corridors for species such as mule deer and elk, and is central to our way of life. Roadless areas are a dwindling resource in the lower 48, and one of the reasons I live in Wyoming is because of our abundant roadless areas. From the Sheep Mountain Roadless Area on the Medicine Bow-Routt National Forest, to the Spread Creek – Gros Ventre River Roadless Area on the Bridger-Teton National Forest, these are areas where I’ve had some of my most formative experiences. Wyomingites will lose something that is a part of us all if roads are built in these areas. I am puzzled that the Forest Service’s Preferred Alternative (Alternative 2) is to rescind the Roadless Rule, when its own analysis in the DEIS points to such an action having many adverse effects. For example, the press release from Secretary Rollins draws heavily on the rationale that rescinding the Roadless Rule will decrease wildfire danger and promote forest health. However, the DEIS states that the frequency and density of human ignitions are approximately four times lower in roadless areas than they are on other lands that are part of the National Forest System (pg. 89). By wiping away the Roadless Rule and opening the door to more road building, we can therefore expect more, not less, wildfire-sparking ignitions. Further, the Forest Service has an existing road maintenance backlog of approximately $6.9 billion (pg. 43). How will the Forest Service maintain the new roads that will inevitably come from rescinding the Roadless Rule, especially with the staff and funding cuts the agency has seen in the past 18 months? The DEIS makes it clear that revenue from increased timber sales won’t cover the bill (pg. 45). The Forest Service’s preliminary biological assessment concluded that rescinding the Roadless Rule will adversely affect 327 threatened and endangered species (pg 25). National Forests are managed for multiple uses, which include wildlife and watershed protection. In this light, adverse impact to hundreds of threatened and endangered species is simply unacceptable. Any management decision that will cause this much harm to ecosystems needs to be rethought. Finally, the DEIS states that rescinding the Roadless Act will jeopardize the quality of drinking water for 24 million Americans (pg. 121) due to increased soil erosion, runoff, and sediment pollution (pg. 108). As someone who lives in a town that gets its water from a National Forest watershed, this action directly jeopardizes the health of my family and community. The Roadless Rule was overwhelmingly supported when it was created in 2001 (95% of the public comments were in favor of the rule at that time) and it remains popular today (99% of the public comments were in favor of the rule when the Forest Service first announced its intention to rescind the rule last year). I know why my friends and neighbors support the rule. It’s a common-sense measure that preserves some of the few remaining wild landscapes in the western US, it protects my drinking water, and it ensures that the wildlife that feed our community and collective consciouses have habitat to thrive. I’m a voter, a taxpayer, a Wyomingite, and I’m watching closely. I urge you not to rescind the Roadless Rule. Sincerely, James Mauch

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. A longer version of this comment is attached. I am a private citizen and a user of forests this proposal affects. The Medicine Bow National Forest was my regular weekend hiking destination from 2020 to 2022. I made roughly six trips to the Manti-La Sal National Forest west of Monticello, Utah between 2017 and 2024. Both contain mapped inventoried roadless areas that this proposal would open to road construction and timber harvest. 1. The DEIS misattributes the cause of untreated fuels. The 2001 rule already permits hazardous fuels reduction in inventoried roadless areas. It restricts road construction, road reconstruction, and commercial timber harvest. It does not bar the fuels work the Department calls urgent. The Department's own figure, that only 5 percent of high-hazard roadless acreage has been treated since 2014, is offered as proof the rule is the obstacle. It shows the opposite. If treatment was permissible for 25 years and did not happen, the binding constraint was appropriations and agency capacity, not regulation. The DEIS should disclose how many fuels projects in inventoried roadless areas were actually denied, withdrawn, or narrowed because of the 2001 rule. Absent that record, the causal premise of this rulemaking is unsupported. 2. The DEIS does not adequately analyze roads as a source of fire. The proposal treats road access only as a suppression benefit. Roughly 89 percent of US wildfires are human-caused, and published research finds ignitions substantially more likely near roads, with ignition probability declining steeply with distance from them. Separate analysis finds that inventoried roadless areas have not burned at higher rates or severity than roaded national forest land. If roadless areas are not burning worse, and roads elevate ignition risk, the final EIS must weigh new ignitions created against suppression access gained and disclose the net effect. 3. The proposal produces arbitrary outcomes that contradict its own rationale. The Medicine Bow-Routt National Forest is a single administrative unit spanning the Wyoming and Colorado line. Under this proposal the Routt side retains protection under the 2012 Colorado Roadless Rule and the Medicine Bow side loses it. One forest, one continuous set of watersheds, wildlife corridors, and big game ranges, divided into two management regimes by a political boundary. The same occurs on the Caribou-Targhee across the Idaho line, and within the Manti-La Sal itself at the Utah and Colorado line. This is not local, context-specific decision-making. It is an artifact of which states petitioned for state-specific rules two decades ago. The DEIS should analyze the ecological consequences of bisecting contiguous roadless landscapes along state lines and explain how that result serves the stated purpose of this rulemaking. 4. The range of alternatives is inadequate under NEPA. A choice between full rescission and no action is not a reasonable range. The DEIS should analyze intermediate and more protective alternatives, including a targeted amendment permitting site-specific exceptions in the wildland-urban interface while retaining core protections, a funding and capacity pathway that achieves the Department's stated fuels objectives within the existing rule, and an alternative extending roadless protection to additional qualifying lands. 5. Irreversibility and the maintenance backlog. Road construction in a roadless area is an irreversible and irretrievable commitment of resources requiring disclosure under NEPA. Roadless character does not return on any human timescale. The agency carries a road and bridge maintenance backlog of approximately 6.9 billion dollars. The DEIS should explain how the agency intends to maintain new roads when it cannot maintain the roads it has, and should account for the long-term erosion, sedimentation, invasive species, and watershed consequences of an expanding and underfunded road network. 6. The comment period is inadequate for the scale of this action. Thirty days for a proposal affecting approximately 44.7 million acres falls well short of the 60 to 90 days customary for a Draft Environmental Impact Statement of this magnitude, and it materially limited my own ability to review the analysis. I join the request from members of Congress to extend it. Inventoried roadless areas are roughly 2 percent of the land area of the United States. They are what remains after a century of road building. The reason most national forests show no roadless areas on the map is that the roading already happened. These places are worth keeping in the condition they are in. I ask that the Department withdraw this proposal and retain the 2001 Roadless Area Conservation Rule. Respectfully submitted, Levi Wright

Dear USDA Forest Service, I am writing to ask you to maintain the 2001 Roadless Rule. As an outdoor recreationist, avid outdoorsman and skier who regularly visits Pisgah National Forest and Medicine Bow-Routt National Forest, I am concerned about the proposal to rescind these protections. The Roadless Rule protects backcountry landscapes that provide clean water, wildlife habitat, outdoor recreation, climate resilience. For me personally, I tremendously enjoy hiking, skiing, and exploring the rivers in these pristine forests. Losing these protections would threaten not only my experiences but also the health and economy of my community. The Roadless Rule is a balanced policy. It allows fire suppression and necessary management, while preventing unnecessary new road construction that fragments forests, which increases wildfire risks, and damages water quality. Repealing this national safeguard would put more than 45 million acres of public lands at risk. I urge USDA to keep the Roadless Rule in place and reject this proposal. Our National Forests should remain resilient, healthy, and undeveloped for future generations.

It is with great concern that I am commenting on the recinding of the current legislation on Roadless Area Conservation. As an avid backcountry recreationist and outdoor enthusiast, I would be remiss to not make my voice heard. In the Colorado front range and Northern mountains alone, from the Medicine Bow-Routt National Forest and Arapaho-Roosevelt National Forest, to the Pike-San Isabel National Forest and White River National Forest, the hundreds of miles of mountain bike, hiking, climbing access and ski terrain that would be impacted by rescinding of this legislature would be devastating to the outdoor community. There are countless recreational backcountry ski areas, for example, like the East Portal/Moffat Tunnel backcountry zone in the Arapaho-Roosevelt National Forest that afford thousands of backcountry skiers and snowshoers access through the winter to recreate. The San Juan National Forest, arguably the most pristine and beautiful wedge of the state, offers critical habitat protection for elk, moose and black bears, and is home to some of the most striking hiking trails in the State. I recognize that this proposed rule change by the Forest Service does not immediately include Colorado, which has taken ownership into its own State hands, but it sets a precedent for which I fear Colorado law makers may also follow, to allow for more mining access. I strongly believe that a full recission will cause irrevocable damage to critical wildlife habitat, and result in the destruction of millions of acres of reactional land used for the benefit of the community. Please consider the community and rich ecosystems that will be impacted by that proposed rule change, and take NO ACTION, leaving the current legislation as is, and has worked since 2001.