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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 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

My name is Kylie Kitchin, and I live in Westminster, Colorado. I spend my free time outdoors on the Front Range and in the Colorado mountains, hiking, camping, disc golfing, and more. I am writing to strongly oppose the proposal to rescind the 2001 Roadless Rule. I recognize that Colorado manages its roadless areas under its own state-specific rule. I am writing anyway because national forests belong to every American, and what happens to them in other states matters to me. The rule protects nearly 45 million acres of national forest from road construction and commercial logging. These forests provide habitat for more than 500 imperiled species, and they are the headwaters for rivers that supply drinking water to over 60 million people in 33 states. Roads and logging in these watersheds bring sediment and pollution into the water communities depend on. The proposal is often framed as a wildfire solution, but the research points the other way. Studies have found wildfires are far more likely to start in areas with roads than in roadless tracts, largely because roads bring more people and more ignition sources. Opening these forests to development would not make communities safer. I also want to flag the process. A 21-day comment period is far too short for a decision this consequential, affecting land that belongs to all of us. I urge the agency to extend it. I respectfully ask the agency to: •Keep the Roadless Rule in place as written. •Extend the public comment period so more people can weigh in. •Direct funding toward maintaining existing roads and trails before building new ones. •Make any site-specific changes through forest planning, with real public input. I recently camped in Routt National Forest, and it was absolutely majestic. I will definitely be back. Colorado chose to put lasting protections in place for its backcountry, and places like Routt are better for it. Other states' forests deserve the same certainty. Once a road is built and a forest is logged, we cannot get that back, and I want these places to stay intact for the next generation of campers and hikers. I urge you to protect the Roadless Rule for the clean water, wildlife, and public lands that millions of us rely on. Respectfully, Kylie Kitchin

I absolutely oppose rescinding the Roadless Rule. While there is a place for prescribed logging in fire prevention, our public lands, National Parks, National Forests and BLM lands, and National Monuments deserve continued protection. I have lived in 13 states, spent the majority of the first 40 years of my life in the West, CO, WY, CA, WA, and New Mexico. I spent several years in college assisting in public comments on Draft Land Management Plans for all 7 of CO's National Forests. I spent a summer documenting unmapped roads in the Routt National Forest in northwest CO, those old logging roads that the Forest Service wasn't sure were still there, or what shape they were in, and how they were being used At that time in the mid 90s, they were still using aerial maps from the 1970s. We documented hundreds of miles of forgotten roads, because the Forest Service was so understaffed they no longer knew what was there. In addition, our research into the myriad ways Backcountry and off road motorized recreation can and does impact wildlife, was eye opening and alarming. The sound of ATVs can rupture the eardrum of a desert tortoise. The same sound in to close proximity can cause female elk to self abort. I have witnessed the effect of logging roads cutting into hillsides in WA, CO, and NM, as well as the devastation of fires and the aftermath, mudslides. For the last 15 years I have lived at the base of the Southern Appalachians in NE TN, about 40 minutes from Western North Carolina. This is an entirely different mountain range than the West, and no less precious. With Helene this region experienced over 2200 landslides. The risk for more comes with every rain. The idea of opening up the Pisgah, Nantahala, and Cherokee National Forests to logging and mining just makes me ill. Anyone who thinks building more roads on these steep hillsides is a good idea has never spent time in the mountains. This entire region is older than the United States, there are species here found no where else in the world, and we must protect it. We are still recovering from Helene. 14 bridges went out in my county alone and they have not all been rebuilt yet. The Roadless Rule helps protect our most precious gift as Americans, our Public lands. Keep them Roadless, so they may still thrive.

Dear Chief Tom Schultz: As someone who has navigated public land on foot for most of my adult life, I know what the absence of roads does for a place. Losing roadless spaces deprives people like me of a place to escape the near-ubiquitous sound of motors and impact of vehicles. Regarding the Pagoda Peak in the Routt NF, Colorado: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Rescinding the Roadless Rule would open the Pagoda Peak, Routt NF 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 have a character all their own. There is a stillness, an undisturbed quality, and a solitude that is destroyed by the intrusion of roads. Keep the Roadless Rule on the books. With kind regards, CommentID: RLC-20261006-DOHR5Q

Dear Secretary Rollins, I am a human, and a part of nature. I want a sustainable future which includes clean water. Rescission will mean I lose a sense of freedom. This is truly an area I feel connected, grounded, and free. That is because of the quiet, the wildlife, the trees, and the mountains. It also impacts more than one spot. Rescinding the Roadless Rule means an increase in fire danger and negative impacts to water quality, both of which are of high importance. Regarding the Dome Peak in the Routt NF, Colorado: Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. 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. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. “Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2)” “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” “Foundational environmental analysis documenting 58.5 million roadless area acres and comprehensive effects on soils, water, fish/wildlife, and socioeconomics. Core scientific record behind the Roadless Rule. — (2000/2001) (https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5057900.pdf)” These are public lands. Keep them whole. Respectfully submitted, CommentID: RLC-20261005-ZWI59Q

"I'm commenting on the proposed rescission of the 2001 Roadless Rule. I oppose this proposal because public lands are for all of us, and they need to be preserved for future generations. Opening roads in these places will destroy their natural beauty, endanger wildlife, and change the natural landscape of wild places that we enjoy and love via our tax dollars. These public lands matter to me because I grew up near a national forest in Michigan, and it shaped who I am as a person. My brothers and I spent countless hours in these woods--riding our bikes, making forts, looking for salmon in the creeks, enjoying the maples in fall, and having a quiet space to disconnect. As an adult I moved to Colorado, and just last weekend we spent three nights enjoying Routt National Forest hiking in the golden aspen, watching the sun set on the mountains, and waking up to an eagle hunting in the stream far below our campsite. Public lands are public and should remain pristine. l'd like the Forest Service to consider the impacts on wildlife, bird migration, and damage to our public lands before making a final decision. Please keep these public spaces ROADLESS as they are for all of us, and I want my kids' kids to enjoy the same magic that I did not only as a child, but as an adult.

I object to the proposed recission of the Roadless Rule. As a vacation homeowner adjacent to Routt National Forest, I am very concerned regarding wildfires. Wildfires are more likely to be initiated in areas with roads than roadless areas. Building more roads into roadless areas will lead to more wildfires. The Forest Service currently has more roads than it can keep in good shape, so building more now does not make sense.

Hello, I am writing to express my strong opposition to RIN 0596-AD66 and its attempt to rescind the 2001 Roadless Area Conservation Rule. This rule has protected and conserved the most important chunks of land to me, my family, and many of my friends for 25 years. In a world of constant development and growth, while necessary, it is an absolute breath of fresh air to escape the noise and recreate on my undisturbed public lands with friends and family. This attempt to rescind the roadless rule came as a shock to me since the reasoning appears to be contradictory to the language the Roadless Rule already outlines. Areas protected under the Roadless Rule are not unmanaged. Every area I recreate in that is protected by this rule allows grazing, important wildlife and wildfire management/mitigation activities, and allow every outdoor recreation opportunity you can think of. Also, counter to popular belief, they even have roads, trails, and two-tracks that are open to motorized and nonmotorized travel. How crazy is that?! Claims that rescinding the Roadless Rule is required to reduce wildfire risk are unfounded. The rule already permits fuel‑reduction treatments and other management actions without adding permanent roads. Moreover, recent research shows wildfire ignitions occur roughly four times more frequently near roads than in roadless areas, indicating that expanding road networks does not inherently lower wildfire risk. The Roadless Rule is also practical financially. The Forest Service already manages about 370,000 miles of roads and carries roughly $10.8 billion in deferred maintenance, with more than half tied to roads. Adding more roads and long‑term upkeep would only increase those costs rather than fixing the financial crisis our country is approaching with $40 trillion of national debt. I support active, science‑based forest management to improve wildfire resilience, forest health and responsible access. But eliminating the Roadless Rule outright is not the solution. Doing so would strip long‑standing protections from more than 44 million acres of national forest backcountry across 37 states. Lastly, I want to share a specific example of the public land that matters most to me and that would be at risk if the Roadless Rule were rescinded. I grew up in Wyoming spending time on 29,659 acres of Forest Service land in the Medicine Bow–Routt National Forest in southeastern Wyoming. This is where I went on my first elk hunt with my dad at age twelve, and it is still where I choose to hunt today. The best elk habitat is inside the Roadless boundary, and it is extremely difficult to find elk near busy roads or infrastructure. As context, about 58 percent of the current elk range is on land protected by the Roadless Rule. This area is not only one of my favorite places to hunt, but also where I went on my first date with my wife. It is where my friends and I take our 4x4s and ATVs on Forest Service Road 211–again, crazy that there are road in Roadless Rule areas–, which is the most fun technical route I have found in Wyoming. It also holds my favorite lake to fish and sits next to the best dispersed campsite I have ever used. Moose, elk, and deer are abundant here, and I value these animals deeply as an outdoorsman and Wyomingite. Medicine Bow Peak rises in the center of this landscape and offers outstanding hiking, climbing, backcountry skiing, and technical mountaineering. On long weekends, this is where nearly everyone I know from southern Wyoming and northern Colorado goes to spend time outside. I come here to use the 15 miles of hiking trails on long weekends for backpacking trips with my wife and dogs. I have attached a map of the area for reference. Removing protections from this landscape would be a profound loss for me, my family, my friends, and countless others. For these reasons, I respectfully ask that the 2001 Roadless Area Conservation Rule remain in place. Thank you, Logan Opsal

To the Department of Agriculture and the Forest Service: As someone who has spent almost two decades enjoying this area and raising my children here, I value these forests and the protections provided by this rule. I have found peace and connection by enjoying this area. If this rule is rescinded, it become more at risk of wildfire, threatening my home, my community, and generations' abilities to enjoy recreating in the area. Regarding the Dome Peak in the Routt NF, Colorado: Dome Peak contains the headwaters of Hinman Creek, Coulton Creek, Lester Creek, Cabin Creek, and Farwell Creek—a network of cold, high-elevation streams that feed into the Elk River system and ultimately the Colorado River basin. These headwaters are critical spawning and rearing habitat for four federally endangered fish: bonytail (*Gila elegans*), Colorado pikeminnow (*Ptychocheilus lucius*), razorback sucker (*Xyrauchen texanus*), and humpback chub (*Gila cypha*, federally threatened). The cold water temperatures and clean spawning substrates maintained by intact riparian vegetation and undisturbed stream channels in this roadless area are irreplaceable for these species' survival across their entire range. Greater Sage-Grouse in the Dome Peak IRA depends on the unroaded landscape to moderate exposure to 7.1 - Fire & fire suppression. Road construction in this area eliminates the spatial buffer between the threat source and occupied habitat. NEPA requires the agency to take a hard look at the effects of rescission on Greater Sage-Grouse (Centrocercus urophasianus) in the Dome Peak IRA. The DEIS fails this standard without site-specific analysis of 7.1 - Fire & fire suppression at the severity and scope documented by NatureServe. "Road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations. The global extent of the problem is substantial and factors affecting the number of animals killed on highways include life-history traits and landscape features. Secondary effects include genetic isolation due to roads acting as barriers to migration. Long-term effects of roads on population dynamics are often severe and mitigation methods include volunteer rescues and under-road tunnels. Despite the development of methods that reduce road kill in specific locations, there is scant evidence that such measures will protect populations over the long term." — Conservation Biology (Wiley), 2013 Unreconciled Contradiction Between Road-Access Fire Rationale and IRA Ignition-Density Data The Draft EIS never reconciles its own comparative fire data with its road-access rationale for rescission. On the one hand, the document states that "the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands," and its Wildfire Occurrence discussion reports IRA ignition density at "12 fires per million acres per year," compared to "42 fires per million acres per year" on other NFS lands—roughly 3.5 times higher. Yet elsewhere the DEIS suggests increased road access under Alternatives 2 and 3 will aid fire management, without addressing whether more roads will instead push ignition density in currently roadless areas toward the higher rate already observed on roaded lands. This is precisely the kind of internal contradiction agencies must resolve under Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002); and Seven County Infrastructure Coalition v. Eagle County (2025), consistent with APA 5 U.S.C. § 706(2)(A). I request a dedicated section reconciling these figures before finalization. Let the Roadless Rule stand. Best, CommentID: RLC-20260906-LOHWR7

Docket ID: FS-2025-0001Title: Comments on the Proposed Rescission of the 2001 Roadless RuleI am writing as a citizen who deeply values our public lands to express my strong opposition to the proposal to rescind the 2001 Roadless Rule. Protecting roughly 45 million acres of untouched forest across the country is not just a policy preference for me—it is a deeply personal issue.Protecting the Heart of Our Wild Spaces and the Routt National ForestOur inventoried roadless areas are the last remaining sanctuaries of quiet and ecological health in our national forests. Living near and exploring the Routt National Forest, I see firsthand how vital these undeveloped backcountry areas are. They provide critical, unbroken habitat corridors for elk and deer, shield pristine watersheds that supply our local communities with clean drinking water, and offer places of unmatched quiet away from modern development. If we open these remaining roadless blocks to industrial logging and road building, we cannot undo the damage. Once a wild space is fragmented by roads, its unique wilderness character is lost forever.Challenging the Claims on Wildfire ManagementI am deeply concerned by the administration’s claim that repealing this rule will somehow improve wildfire management. This argument simply does not match the reality of forest ecology or common sense:Roads Bring Fire Risks: More roads mean more human access, which heavily increases the chances of accidental, human-caused ignitions in remote areas that are currently protected.Logging Doesn't Solve the Problem: Permitting commercial timber harvesting under the guise of fire safety is misleading. Taking out large, mature trees and leaving behind dry, flammable debris actually creates hotter, drier, and windier conditions that allow fires to spread faster, not slower.We Already Have Safety Tools: The existing framework already allows forest managers to do necessary fire mitigation and handle emergencies. Stripping away the entire rule feels like an excuse to let commercial timber interests into places they don't belong, rather than a genuine effort to protect communities.ConclusionIf we want to protect communities from fire, we should focus our funding and energy directly around the towns and homes in the Wildland-Urban Interface—not miles deep into pristine backcountry like the roadless zones of the Routt National Forest. I urge you to listen to the citizens who love and depend on these wild spaces and leave the 2001 Roadless Rule fully intact.