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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Colorado holds 4,407,277 acres across 326 inventoried roadless areas, and the people of this state have made clear what those landscapes mean to them. Ninety-three percent of Colorado's residents watch wildlife, most of them every day. They understand that abundant, healthy, well-managed wildlife populations improve quality of life, and that well-planned conservation and protection of natural resources makes Colorado a great place to live, work, and recreate. I share that view, and it is the foundation of this comment opposing the proposed rescission of the 2001 Roadless Area Conservation Rule. The Pike-San Isabel National Forest holds two of the roadless areas I am writing through: Old Monarch Pass, at 19,531 acres, and Porphyry Peak, at 3,394 acres. Old Monarch Pass already provides access through a backcountry road experience. Another road would not provide a different experience, and the case for protecting the Pike-San Isabel from unnecessary development does not require elaboration beyond that. At Porphyry Peak, Colorado's high mountain tundra is easily damaged by vehicle traffic across sensitive tundra plants, and off-roaders in this state already have a wealth of places to pursue motorized activities. The 3,613-acre Dorsey Creek area in the Rio Grande National Forest sits at the headwaters of drainages that supply clean water downstream. Colorado is the headwaters for much of the nation, and clean, clear streams like Dorsey Creek provide a resource we simply cannot live without. Across the Rocky Mountain region, 325 municipal water intakes sit in watersheds containing affected roadless areas. The agency must explain, specifically and directly, what this rescission means for the integrity of those watersheds and what substitute protections, if any, it proposes. The agency's own language undermines its stated justification on wildfire. The 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." I ask the agency to explain why the proposal departs from that prior finding, and to reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is equally difficult to sustain on the agency's own numbers. The record acknowledges: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, all while the existing road system carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with those figures and explain how expanding a system it cannot afford to maintain serves the public interest. The legal history here is not favorable to rescission either. The agency's own record recounts that "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." That dissatisfaction was tested in court, and the state-by-state approach that replaced the national rule was struck down. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time this substitution was attempted. On the question of statutory authority, the Tenth Circuit has already spoken: "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." That court held the 2001 rule was within the authority Congress granted and did not create de facto wilderness. The agency must explain the legal basis for any contrary position. We don't need more roads. We need more Wilderness. The agency should respond to each of the concerns raised here and place those responses in the public record before any final action is taken. Sincerely, John Koshak Penrose, CO

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

I am strongly opposed to the elimination of the roadless rule on public lands. I have lived in the Rio Grande National Forest, walking distance from the designated Weminuche Wildnerness, as well as the Coconino National Forest. There are already plenty of roads for resource extraction and recreation. More roads means more logistical, maintenance, and pollution problems. The reason these lands are protected is because they have things like nowhere else. More roads is not the answer to the problems of public lands. This was one of the most commented on and supported rules when it was proposed about twenty years ago. Do not change the rule now. It is still overwhelmingly popular with the people who live in and visit these places and surrounding communities.

To the Forest Service: I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR part 294, subpart B). I haven been an avid hike for almost 20 years, hiking several times a week (or more). This includes national parks and national forests including the following: • Angeles National Forest • Arapaho National Forest • Carson National Forest • Cleveland National Forest • Inyo National Forest • Lassen National Forest • Pike National Forest • Rio Grande National Forest • Roosevelt National Forest • Routt National Forest • San Bernardino National Forest • White River National Forest Hiking is important to both my physical and mental health and has played an important role in my volunteer work to help veterans reintegrate following their service and find community. Taking them on hikes has been a powerful way to bolster their health and wellness. The 2001 Rule protects roughly 58.5 million acres of inventoried roadless areas by generally prohibiting road construction, road reconstruction, and timber harvesting, with limited exceptions. Rescinding it removes that protection nationwide. The notice states that the rescission does not itself mandate timber cutting or road building. But it removes the rule that currently prevents them, and the agency should be candid that this makes road construction and logging in these areas possible where they are now generally prohibited. For hikers, the value of these areas is that they are undeveloped. A trail through a roadless area offers quiet, solitude, and a sense of remoteness that cannot be rebuilt once a road is cut through. Opening the door to new roads and logging puts those experiences at risk, and the loss would be permanent in a way that is very hard to undo. The Department's stated reasons for the proposal are to reduce regulatory burden and to return decisions to local Forest Service officials. I ask the agency to address the following in the final rule and EIS: How will recreation be weighed? If decisions move to the local level, what required standard will ensure that the value of undeveloped backcountry for hiking and other dispersed recreation is considered, rather than left to discretion project by project? What is the burden being relieved? Please identify the specific, documented costs of the 2001 Rule, and show that they outweigh the benefits of keeping a consistent nationwide protection. Why rescind rather than amend? If there are specific problems with the rule, why does the Department propose eliminating it entirely instead of a narrower fix? How will the public be involved? Under the proposal, how would hikers and other recreation users learn of and comment on future decisions affecting individual roadless areas? I also ask that the Department give the public adequate time to review a proposal of this size. The rescission was issued alongside a draft environmental impact statement and a cost-benefit analysis, with an original 30-day comment period. I urge the Department to withdraw the proposed rescission and keep the 2001 Roadless Area Conservation Rule in place. Sincerely, Laura W. Fort Collins, CO

I am writing to express my strong opposition to the Forest Service’s proposal to rescind the Roadless Rule. I am an avid outdoor recreationist who regularly visits roadless areas in America's national forests. For the last 55 years I have camped, hiked and backpacked in most of Colorado's National Forests, doing many trips each year in the White River National Forest, Rio Grande National Forest, Arapahoe National Forest, Roosevelt National Forest, Pike National Forest, San Isabel, and San Juan National Forest. These are some of the main ones. I have also hiked, camped and backpacked in Wyoming's national forests such as the Teton National Forest, Bridger National Forest and Bighorn National Forest. I have also hiked and backpacked in much of southeast Utah. Most of my backpack trips are from 4 to 12 days covering 40 to 100 miles per trip. I have enjoyed all the beauty the National Forests have to offer such as the wildlife, fishing and clean water that is presently there. This is where I rejuvenate, refocus and clear my head. Logging and road building would spoil these untouched, pristine National Forests and they must remain roadless. The roadless National Forests help provide clean drinking water to downstream communities, are home to cold, crystal-clear trout fishing streams, boast world-class hiking and mountain biking trails, support local businesses, provide habitat for at-risk animal species, and offer unmatched experiences for visitors looking to get away from the noise and commotion of roads. I believe that road building for logging in the National Forests would do long-lasting damage to these incredible public lands, to the wildlife, water and to communities that benefit from them. The financial gain would not justify the damage. As far as management goes what could be less complicated than managing all the national forests through one simple and clear mandate of the current roadless rural. Why fragment the management which would occur for each individual National Forest. Think of all the increased litigation that could result when each National Forest has its own management rules and is litigated separately. I strongly urge you to keep the Roadless Rule in place as-is, so that future generations of hikers, anglers, mountain bikers, hunters, climbers, birders, and paddlers can enjoy these amazing roadless places. Thank you for considering my thoughts Tom Lohaus Colorado

October 3, 2026 Comments on the proposal to rescind the Roadless Area Conservation Rule. Docket # FS-2025-0001. My name is Suzanne DeVore and I live in Mosca, Colorado at zip code 81146. I am a voter. I am an avid hiker, walker, bicyclist, Nordic and downhill skier, camper and birder. I spend a ton of time every year recreating on public lands. It is my understanding that despite 99% public opposition to its rollback, the Administration moved forward with its intent to rescind the 2001 Roadless Rule by publishing a Draft Environmental Impact Statement (DEIS). I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I strongly support Alternative 1, the No Action alternative. I love spending time in the National Forests near where I live in southern Colorado. Including the Rio Grande National Forest, the San Juan National Forest, the Gunnison National Forest and the San Isabel National Forest. I am fortunate to be able to walk to the Sangre de Cristo Wilderness from my home. I also spend weeks camping in the neighboring state of Wyoming. I particularly love the Medicine Bow National Forest and the dramatic Snowy Range in southern Wyoming. I also love to camp in the Bighorn National Forest and backpack in the Wind River Range. My husband is an avid fly-fisherman, so this determines a lot of the places we visit! We like to travel to the Coronado National Forest in Arizona for hiking and cycling during the winter. We particularly love the areas in and around the Chiricahua mountains. This proposal is just ludicrous for many reasons, but mainly because the current road system is stressed now! The U.S. Forest Service lacks the capacity, in funds and workforce, to support its existing roads, much less an increased inventory of roads. There are plenty of roads now. Roads cause excessive erosion and siltation to streams. Most of America's clean, fresh watersheds start in national forests. In this time of changing climate and severe droughts the current rule protects our valuable drinking water. Roadless areas help keep invasive species at bay and prevent pollution. The DEIS details many points on this topic. The current rule protects intact ecosystems for American wildlife. Roadless areas provide habitat for vulnerable wildlife species, including the Canada Lynx in our area. These roadless landscapes, often adjacent to other protected areas, like wilderness, are critical for habitat connectivity and health. Roads severely impact birds and wildlife. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird variety and abundance. It is vital to avoid fragmentation of the roadless areas. The DEIS cites the finding that habitat fragmentation reduces biodiversity. Wildlife tend to disappear when forest cover thins; many avoid roads used by winter machines. The DEIS notes that wide-ranging mammals like the grizzly bear “have suffered habitat loss and the extirpation or fragmentation of their populations.” It is false that building more roads will help fight wildfires. Studies show that more roads do not lead to better forest health through increased fire-management activity. Conversely, Wildfire incidents happen near roads. Studies show that 90% of wildfires happen within 1/4 mile of roads. If more roads led to more fires, this action would increase the number of incidents, not improve response, as suggested. Our National Forests sustain some of our nation’s last stands of old growth forest. Here in Colorado our nearby Rio Grande National Forest and all the national forests across the United States are an economic boon for tourism and for well-planned and regulated timber sales. No new roads are required to support these benefits of the forest. It is widely recognized that the purpose of changing the roadless rules has nothing to do with forest health as it is proclaimed to do. The purpose is to reduce regulatory burden and return decision making to local officials, not U.S. Forest Service experts with years of education and experience managing our forests for all U.S. citizens. This proposal is a callous, greedy attempt to provide access to our public lands for oil, mining, timber and other extractive industries! It’s sacrificing our forests to make a few wealthy elite people richer. It would bring short-sighted and short-term benefits to these few, while ruining long-term, irreplaceable lands that belong to all of us, the public. I completely oppose the proposal to rescind or alter the Roadless Rule, and strongly support Alternative 1, the No Action alternative. Suzanne DeVore 113 Spring Creek Drive Mosca, CO 81146

Forests do not stop at state lines. While Colorado's 4.4 million acres of roadless areas are exempt from this move, the state can still amend protections for temporary roads, as done in 2017 with the North Fork Coal Mining Area. Colorado national forests connect critical habitat with other pristine landscapes on three of its borders. This includes the Rio Grande National Forest, with roadless areas acting as "stepping stones" from the Carson National Forest in New Mexico. Most of these connected forests sit along the northern border into Wyoming. Both of these connect to the Continental Divide National Scenic Trail (CDT).

Attention: U.S. Forest Service / USDA Re: Proposed Rescission of the 2001 Roadless Area Conservation Rule (Docket Number: FS-2025-0001-223869)I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. This framework has successfully protected intact ecosystems across America for 25 years. This issue hits close to home. My backyard is the Rio Grande National Forest in Colorado. I spend my time fishing along the Rio Grande in Rio Grande County, relying on clean water filtered by intact forests. I mountain bike on BLM land in the Spanish Trails area between Monte Vista and Del Norte, and head deep into the backcountry hunting dusky grouse and white-tailed ptarmigan in wild, high-altitude alpine areas between South Fork and Lake City. Living alongside this landscape, I see daily how vital roadless spaces are to our ecology, wildlife, and balanced lifestyle. Stripping foundational national framework protections to satisfy short-term extraction threatens land management integrity everywhere. I urge the Forest Service to maintain the Roadless Rule based on the following critical points. Looking back, the 2001 rule followed a rigorous process with over 600 public hearings. It generated over 1.6 million public comments—the largest response to federal rulemaking at that time—with over 95% of commenters voting in favor of keeping these areas protected. The public mandate remains clear. Secondly, the benefits of keeping these lands wild extend far beyond those of us lucky enough to live near them. Even Americans living thousands of miles away benefit from these healthy ecosystems. Roadless forests act as the nation's lungs and water towers, filtering the clean air we breathe and securing headwaters providing pristine drinking water to tens of millions downstream. From a financial standpoint, rescinding this rule makes no sense. The Forest Service struggles with a national road maintenance backlog exceeding $4.5 billion. The agency cannot maintain its current infrastructure. Rescinding the rule forces taxpayers to fund new, unwanted logging roads while existing public recreation access roads continue to deteriorate. Moreover, the claim that roads reduce wildfire risk is contradicted by science and the Forest Service’s own DEIS data, which shows fire frequency is significantly lower in roadless areas. Studies show 85% to 89% of wildfires are human-caused, mostly starting within a half-mile of a road. New roads act as ignition corridors and dry out vegetation, increasing fire risk rather than reducing it. Furthermore, our backcountry is a vital lifeblood. The San Luis Valley (SLV) is a globally recognized stopover for thousands of migrating Sandhill Cranes and waterfowl. These birds depend on undisturbed watersheds flowing directly out of Rio Grande National Forest roadless areas. Elk, mule deer, and bighorn sheep depend on unbroken corridors to navigate between summer alpine ranges and winter valley grounds. Road development fragments habitat, causing extreme stress and disrupting traditional migration patterns. Additionally, our rural communities surrounding the Rio Grande National Forest rely on a robust, recreation-driven economy. Our local economy thrives because of a balanced approach that grants equal, sustainable access to a diverse tapestry of users—from mechanized trail riders to traditional hunters and anglers. The Roadless Rule preserves the high-quality backcountry experiences that draw global visitors, whereas prioritizing industrial resource extraction directly threatens local tourism economies. Lastly, we are standing at a critical crossroads. We can either continue to ignore the obvious signs that a changing climate is already threatening our public lands and our way of life—knowing that rescinding this rule will only accelerate habitat loss, increase fire starts, and worsen ecological degradation—or we can choose to step up. We must keep this rule firmly in place and preserve these beautiful, intact spaces. Doing so fulfills our responsibility to protect the land we all share, recognizing that we are not separate from nature, but part of the entire interconnected ecosystem. Ultimately, the Forest Service must face a fundamental question about its legacy: What do we want to be remembered as—stewards or exploiters? I strongly urge the Forest Service to keep the 2001 Roadless Area Conservation Rule completely intact. Sincerely, Iris Devlin

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I lived in the San Luis Valley of Colorado for 40 years and hiked, camped, fished, skied, and built and maintained trails in the Rio Grande National Forest, particularly in the South San Juan Wilderness and the Weminuche Wilderness. It took decades of work to create these wilderness areas by people who understand their importance. Having uninterrupted wildlife corridors keeps animal populations healthy and with a larger gene pool. New roads will disrupt migration and inhibit food finding and breeding. New roads will not promote fire prevention, as studies show that human-caused ignitions and fires are more frequent near roads. Extraction of fossil fuels and minerals is detrimental to keeping watersheds clean. And importantly, due to financial constraints, the Forest Service has been unable to maintain existing roads. Adding to that backlog makes no sense. The Roadless Area Conservation Rule was a hard fought achievement by those of us respect and protect the roadless areas and wildernesses. To destroy that for short term financial gain is shortsighted. Do not pass this rule.

I am writing to strongly oppose removing or weakening the Roadless Rule, particularly because of what these protections mean for Southwest Colorado, the Rio Grande National Forest, and the San Luis Valley. I have spent time in this part of Colorado and have come to appreciate how special it is. One of the things that makes the area different from so many other places is the amount of relatively untouched public land. You can get away from roads, development, and crowds and experience a landscape that still feels wild. I think that is something worth protecting. The roadless areas around the Rio Grande National Forest are not just empty stretches of forest waiting to be developed. They are important habitat, watersheds, and recreation areas. They support the wildlife and outdoor opportunities that make Southwest Colorado such a special place. I especially value these areas for hiking, fishing, hunting, camping, and simply being able to spend time in the mountains without constantly encountering roads and development. The San Luis Valley also has a unique relationship with the surrounding mountains. Water is incredibly important to the Valley, and healthy, intact mountain watersheds are part of that equation. I am concerned that allowing substantially more road construction could create unnecessary erosion, habitat fragmentation, and other impacts that would be difficult or impossible to reverse. I understand that the Forest Service has legitimate challenges to deal with, including wildfire, forest health, and public safety. I am not opposed to responsible forest management, and I understand that there may occasionally be situations where access is necessary. But I don't believe that solving those problems requires eliminating protections for roadless areas across the board. To me, the most important question is what we will leave behind. A road can be built relatively quickly, but once an undeveloped landscape is fragmented, it is extremely difficult to put it back the way it was. We have very little reason to assume that future generations will regret having preserved too much wild public land. I think they are much more likely to regret having lost it. Southwest Colorado already has tremendous pressure from recreation, development, and increasing visitation. The roadless areas of the Rio Grande National Forest provide something that cannot be recreated somewhere else once it is gone: large, intact landscapes where people can experience the mountains in a more natural state. I respectfully ask that the Roadless Rule be retained and that the roadless lands of the Rio Grande National Forest and Southwest Colorado continue to receive strong protection. These places have value far beyond what can be measured by the immediate economic benefit of building a road. They are part of the character of the San Luis Valley and a resource that I believe we have a responsibility to pass on intact.

September 8, 2026 Comments to the proposal to rescind the Roadless Area Conservation Rule. Docket # FS-2025-0001. My name is Mark Seaton and I live in Mosca, Colorado at zip code 81146 I am a retired federal employee and worked for several land management agencies during my career. I am an avid hiker, fly fisher, bicyclist, nordic skier and birder. I spend thousands of hours every year recreating on public lands. I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I fully support Alternative 1, the No Action alternative. My wife and I love spending time in the National Forests near where we live. Including the Rio Grande National Forest, the San Juan National Forest, the Gunnison National Forest and the San Isabel National Forest. We also spend weeks camping in Wyoming. We particularly love the Medicine Bow National Forest and Snowy Range. We also love to camp in the Bighorn National Forest and backpack in the Wind River Range. In the winter months we like to travel to the Coronado National Forest in Arizona for hiking and cycling. We particularly love the Chiricahua mountains. The Forest Service cannot afford to maintain the existing roads. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a $6.9 billion deferred maintenance backlog. The supplemental funding is expiring. Maximum projected timber revenue is $5.2 to 11.4 million a year, against up to $6.1 million a year in lost recreation benefit by its own figures, and the agency’s own cost-benefit analysis states a net present value that runs to negative $92 million. Even DEIS states outright that road mileage, deferred maintenance and management costs are likely to increase. Roads cause excessive damage to streams. Skid roads, trails and log landings of timber operations are the main cause of soil erosion and can contribute up to 90 percent of the sediment generated by timber sale activity, and lists the consequences: lost spawning and rearing habitat, lost deep pools and cover, higher egg and juvenile mortality, blocked passage. The waters above these areas are clean today: less than 12 percent of the watersheds holding affected roadless areas have impaired streams. Roads severely impact birds and wildlife. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. It is vital to avoid fragmentation of the roadless areas. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, 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. Marten disappears when forest cover thins; wolverine avoid roads used by winter machines. On big animals, its own words: wide-ranging mammals like the grizzly bear “have suffered habitat loss and the extirpation or fragmentation of their populations.” In this time of changing climate in severe droughts we must protect our water and it’s sources. The DEIS: roads alter watershed hydrology, stream flows, water temperature regimes and stream channel morphology, and water yield and runoff in these areas are generally unaltered from natural conditions today. The affected areas overlap designated Wild and Scenic Rivers in the wild classification. The purpose of changing the roadless rules has nothing to do with forest health. The purpose and need is to reduce regulatory burden and return decision making to local officials, not forest health and not fire. Every conservation alternative was eliminated for failing that purpose: more acreage “would not be responsive to the deregulatory executive orders,” and one option was cut partly because analyzing roadless values is “an administrative and legal burden for the agency.” The agency even monetized what no roads in an area itself is worth to people who never visit: $5.3 to $11.5 million a year forgone, landing in the same range as the timber gain, which is why its own accounting cannot clear zero. And in its own words, “This proposed rescission does not mandate timber cutting or road construction”: nothing about management is promised, only the removal of the protection. This proposal is nothing more than a thinly veiled attempt to provide access to lands for oil, mining, timber and other extractive industries! It’s sacrificing our forests to make the rich richer nothing more. For the reasons listed above, fully or even partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a terrible mistake and would permanently damage our precious forest resources. I completely oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative. Thank you for allowing me to comment. Mark Seaton 719-588-7678

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I hike, camp, and backpack extensively trough roadless areas, and the peace and freedom these lands offer is unparalleled. Maintaining the roadless status of these lands is essential to preserving this quintessentially American public asset for our children for generations to come. My wife and I hiked a portion of the Continental Divide Trail (a National Scenic Trail, established by congress) for our honeymoon. Over 300 miles of the CDT pass through pristine roadless lands on superb trails. Public land should NOT be exploited for the profit of private profiteers who have not stepped foot in these lands and appreciated their unique assets. By building roads through these lands, it increases the amount of human-wilderness boundary and thus increases the likelihood of destructive effects, such as wildfires, floods, land and water degradation, and loss of biodiversity/wildlife habitat. My wife and I recently welcomed our son to our family, and it would make me proud to pass down an America to his generation that has the heritage, history, integrity, and beauty of its public lands intact. The current proposal forces mismanagement onto our public lands and is threat to our American heritage. I live near roadless areas in the Santa Fe National Forest and was evacuated from my home during the Hermits Peak-Calf Canyon fire. Our community does not need the increased fire risk and the burdens that come with it that the current proposals will force onto us. My family has hiked in the Mt Evans area many times and some of our fondest memories come from camping near Abyss Lake, watching the sunsets and sunrises kiss the glorious peaks of Mt Bierstadt and Mt Blue Sky, crown jewels of America's public lands. The Gila is an amazing place to go backpacking, with some of the most pristine wildlife habitat (and its resultant wildlife) I have ever seen. The Bear Mountain area is local to me, and my family and I hike here frequently, taking in the freedom and relaxation that a roadless area provides and enjoying the resurgent forest and its wildflowers and wildlife. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Mt. Evans Adjacent Area (10,247 acres), Arapaho-Roosevelt NF, Colorado - Enchanted Lakes (1,276 acres), Santa Fe NF, New Mexico - Bennet Mountain / Blowout / Willow Creek / Lion Point / Gree (53,053 acres), Rio Grande NF, Colorado - Contiguous To Black & Aldo Leopold Wilderness (111,883 acres), Gila NF, New Mexico - Sawyers Peak (59,743 acres), Gila NF, New Mexico - Candian River (7,149 acres), Cibola NF, New Mexico - Bear Mountain (1,387 acres), Santa Fe NF, New Mexico - Valle Del Toro (1,862 acres), Santa Fe NF, New Mexico 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 of the road construction and timber harvest it would newly allow. Some of the areas named above lie in Idaho or Colorado, where the state-specific roadless rules at 36 CFR 294 Subparts C and D are stated to be retained. For those areas I ask that the agency state in the DEIS precisely how this action interacts with the retained state rules and what, if anything, changes in their management. Additionally, I raise the following issue for the record and ask that the agency respond to these concerns: Issue: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. 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 regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. I 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. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Calj Umezono Las Vegas, NM