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I am writing from my home in Southwest Colorado, where National Forests, and their Roadless areas, are a crucial part of our daily lives and our economy. I strongly oppose the Trump administration’s plans to eliminate the Roadless Area Conservation Rule. This Rule has proved successful for over 20 years. The areas protected by the Roadless Rule include many of American’s Crown Jewels. It protects wildlife habitat, clean water, clean air, and recreational opportunities for hunters, fisherman, hikers, and others. The proposed repeal of the Roadless Rule would threaten these benefits. This rollback would harm the San Juan National Forest near where I live. Much of the local economy relies on pristine forests for hunters, hikers, horsemen, and fisherman to recreate. Our drinking water is dependent on our remote forests. The proposed repeal is being justified as a wildfire-prevention measure. This ignores extensive research demonstrating that additional road construction in our forests would increase wildfires.  Evidence shows than 80% of wildfires occur within 800 yards of roads.  I submit that with the numerous cuts to the National Forest Service’s budget over the last few years, any money spent building additional roads would detract from maintenance of existing roads and trails. Locally we have several existing Forest Service roads which were washed out by flooding a year ago. Resources have not yet been made available to restore these roads, which are important for access to private property, as well as for hunting, fishing, camping, hiking, and riding. If the justification for more roads is to increase timber production, this would likely result in cutting down bigger, old trees, which are the most resilient to wildfire. If old-growth forests are logged, it can take  hundreds of years to regrow. Because older trees store more carbon than younger trees, it is critically important that we keep these forests standing right now while they have the greatest ability to mitigate climate change.  Further, since many of the areas affected by the Roadless Rule are remote and rugged, logging them would be an expensive, uneconomical prospect. Far better to dedicate resources to thinning National Forests near their edges, to mitigate potential fire hazards for local towns and residents.    National Forests belong to the American People and are not simply a crop to be used to  enrich industry executives. They nurture fish, birds, wildlife, and people. They filter our drinking water. The Forests provide  recreational opportunities which support our economy and enrich our lives. In the era of Climate Change, long term drought and drying, once these Forests are logged, they may NEVER regrow. Carving up these forests with roads and logging means we lose those benefits. Our National Forests belong to all Americans, not the timber industry. The Roadless Rule protects an outstanding environment for backcountry recreation. They nurture numerous fish, bird, and wildlife species. They provide subsistence to many local hunters and Native Americans. They protect clean, clear drinking water for our local community. Elimination of the Roadless Rule would threaten  all of those benefits.  I urge you to maintain the current Roadless Rule to protect our forests. Sincerely, Andy Butler Pagosa Springs, CO

I am against rescinding the Roadless Rule. I recreate in many of the roadless areas. Locally, I recreate in the Storm Peak area of the San juan National Forest and the San Miguel area of the San Juan national forest. Roadless areas are critical for me and the plants and animals that live in these areas. I go to these places for solitude and renewal. I go tho these places to learn and study the natural habitat. I am a retired National Park Service ranger with over 28 years of federal government service. The National Parks today are often very overcrowded. I have turned to these roadless area for escape and to enjoy places with very little human impact. Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. The DEIS also quantifies the differential, and the relevant figure is not the one most often quoted. Table 18 (p. 95) reports all-cause ignition density of 42 fires per million acres per year on other NFS lands against 12 in potentially affected IRAs. Table 21 (p. 98) decomposes that figure by cause: human-caused ignition density is 22.4 against 3.0 — a factor of 7.5 — while the natural-ignition rates are far closer at 16.8 against 8.5. The differential the DEIS attributes to roads is therefore the human-caused component, and it is more than twice the size the all-cause comparison suggests. Notwithstanding these findings, the DEIS concludes at p. 113 that "the net impact of new roads on fire occurrence is likely small or insignificant, given the potential for improved response times and increased initial attack success." No source is cited for that conclusion, and no estimate of the ignition increase appears anywhere in the effects analysis for either action alternative. Its two supporting assumptions are unquantified and uncommitted. At p. 109 the DEIS reasons that "not all roads constructed under alternative 2 would be open for public access. Therefore, increased human ignitions do not necessarily follow from increased road construction." At p. 113 it states that "public access to roads constructed or improved under alternatives 2 and 3 can be limited to minimize fire hazard in high-risk areas." Neither alternative commits to any level of access restriction, no proportion of closed roads is estimated, no basis is given for expecting any particular proportion, and the rescission itself transfers that decision to local responsible officials. The analysis thus supplies the mitigating assumption while the rule removes the national requirement that would deliver it. The DEIS states the method for closing this gap and does not perform it. At p. 109: "As discussed in Wildfire Occurrence, past fire occurrence information on NFS lands, inventoried roadless areas, and wilderness can be used to evaluate the potential effects of new road construction." The necessary input is already in the document. Figure 15 (p. 98), "Density of reported ignitions by distance to roads and cause within the potentially affected IRAs," is the ignition-to-road-distance gradient measured inside the affected area itself. Figure 15 appears in the body of the DEIS once, as that caption. No text discusses it and no effects analysis applies it. Because the DEIS announces this analysis, presents the data for it, and then substitutes an uncited qualitative conclusion that runs against its own cited

Dear Brooke L. Rollins, My name is Alex Griffith, and I'm a law student at UNC Chapel Hill. For four years, I lived in Durango, Colorado, and was privileged to have access to the Hermosa roadless area. The ability to have spent so much time in Hermosa, whether on foot, on my bike, or on skis, is one of the privileges of my life. I think specifically about the day I spent summiting Hesperus Mountain in 2023. The Diné people's sacred mountain of the north, it is a truly staggering 13er and that day was a true source of peace and connection for me—one that I return to often. There are plenty of roads adjacent to the Hermosa area. Adding more of them will ruin the peace that so many find in that place, and will damage the land profoundly. Regarding the Hermosa in the San Juan NF, Colorado: The Hermosa IRA, San Juan NF, contains sites of Indigenous settlements and communities that constitute irreplaceable cultural resources. These resources are finite, non-renewable, and directly threatened by the ground disturbance that road construction entails. Road construction requires grading that strips surface soils, cut-and-fill operations that displace subsurface deposits, and heavy equipment compaction that crushes fragile materials in place. Each of these mechanisms independently destroys sites of Indigenous settlements and communities that constitute irreplaceable cultural resources within the Hermosa IRA, San Juan NF. If the agency fails to identify and analyze Historic settlements resources — specifically sites of Indigenous settlements and communities that constitute irreplaceable cultural resources — within the Hermosa IRA, San Juan NF, it will authorize their destruction in ignorance. The DEIS must close this gap before any record of decision issues. "Section 106 of the NHPA requires federal agencies to consider the effects on historic properties of projects they carry out, assist, fund, permit, license, or approve. A fundamental goal of the Section 106 process is to ensure that federal agencies consult with interested parties to identify and evaluate historic properties, assess the effects of their undertakings on historic properties, and attempt to negotiate an outcome that will balance project needs and historic preservation values." — Advisory Council on Historic Preservation Not everything needs to be opened up. Most respectfully, CommentID: RLC-20261005-NX9JDX

Dear Secretary Rollins and Forest Service Officials, I am writing to express my strong opposition to the U.S. Department of Agriculture’s proposal to rescind the 2001 Roadless Area Conservation Rule. As an avid hiker, backpacker, and bikepacker who has traveled thousands of miles across the American West, I have seen firsthand that roadless areas are irreplaceable public treasures. My personal experiences in wild landscapes like the Gila and Santa Fe National Forests in New Mexico, the San Juan National Forest in Colorado, and the Manti-La Sal National Forest in Utah have shaped my deep appreciation for unroaded lands. From years on the trail, I know that introducing roads into these pristine areas only brings degradation and conflict. Based on my observations throughout the West, expanding road networks leads directly to: • Increased Fire Risk: More vehicle and human access significantly drives up the potential for devastating, human-caused wildfires in remote backcountry. • Illegal Dumping & Pollution: Roads invite illegal trash dumping and vehicle contamination, actively spoiling pristine ecosystems. When backpacking or bikepacking, I always know I am getting closer to a motorized corridor or city because of the sudden influx of litter along the trail. • Impacts of Irresponsible Use: Open roads frequently see irresponsible use by trucks, off-road vehicles, and motorcycles, which accelerates trail erosion and disrupts natural habitats. • Loss of Natural Quiet: Vehicle noise pollution shatters the rare, deep peacefulness that can only be found far away from motorized infrastructure. The 2001 Roadless Rule has successfully protected these lands for a quarter of a century. Rolling back these protections will permanently compromise the wild character, clean water, and quiet recreation opportunities that define our National Forests. I urge the Forest Service to withdraw this proposal and maintain the Roadless Rule.

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

I am writing as a private citizen to oppose the rescission of the 2001 Roadless Rule, and to urge the Department to withdraw the proposal. I have spent many days and nights on National Forest (NF) land, from the from Florida to Washington State. Some of my happies and most peaceful memories are from my adventures. It is a true privilege and responsibility we hold to live in a country that has so much protected wilderness. A decade ago I drove from Raleigh, NC to Acadia and back with some friends. While camping in Allegheny National Forest we were able to see beavers and beaver ponds for the first time. But what also struck me was the infrastructure: spurs, skid roads, gates, washed-out ditch lines, and derelict culverts. The Forest Service already manages roughly 370,000 miles of road, and by the agency's own reporting, it carries a deferred maintenance backlog on that system measured in billions of dollars. Undersized and failing culverts are a documented problem across the system. The proposed rescission would open the remaining 44.7 million acres of unroaded NF System land to new construction at a moment when the agency cannot maintain what it built in the twentieth century. The Draft EIS does not, in my reading, adequately grapple with this. A new road is not a one-time cost. It is a permanent maintenance liability and a permanent sediment source, and the agency is already insolvent against the liabilities it has. I have hiked and camped for years in Pisgah, Nantahala, Cherokee, and George Washington & Jefferson NF. These mountain ranges are headwaters that supply drinking water to many water districts. The Forest Service has long stated that national forests supply drinking water to roughly 60 million Americans across the country, and undeveloped watersheds are the cheapest filtration any of those systems will ever have. Forest roads are consistently identified as the dominant chronic sediment source in managed forest watersheds; Luce and Black's work on road sediment production and the broader synthesis by Trombulak and Frissell (2000, Conservation Biology) on the ecological effects of roads on terrestrial and aquatic communities are the standard references. Sediment is also what kills Southern Appalachian brook trout. The remaining wild populations are largely confined to cold, steep, and high-gradient headwater streams. These fish do not survive with the introduction of fine sediment in the spawning gravels, increased water temperatures and passage effects of road crossings. In 2020 I drove through New Mexico, Colorado, Wyoming, Montana, and Utah, camping mostly on national forest land. Camping In the Shoshone and Bridger-Teton NF was a dream come true for an avid hunter and outdoors man. The Big Game tourism is big business in Wyoming and other wilderness areas. Elk habitat effectiveness declines with road density has been established since Lyon's work in the early 1980s, and the security-area concept of Hillis et al. (1991) is built directly on it. Hunters and the hunting industry lose when elk habitat is impacted. From the Southern Appalachia, through San Juan NF, to the Northern Cascades, I have seen time and time again the visible impact along every road I drove. Roads are the number one factor when it comes to the introduction of invasive species. Gelbard and Belnap (2003, Conservation Biology), working on the Colorado Plateau, documented roads functioning as conduits for exotic plant invasion, with improved road surfaces associated with markedly higher exotic cover in adjacent vegetation. Cheatgrass does not arrive on its own. It arrives on tires and on graded shoulders, and it changes the fire regime once it does. The Department's stated justification is wildfire risk reduction. I want to address it directly, because I think it is the weakest part of the proposal. Balch et al. (2017, PNAS) found that humans ignite roughly 84 percent of U.S. wildfires and have tripled the length of the fire season. Ignitions cluster along roads, because that is where people are. Building roads into currently unroaded country does not lower ignition risk in that country. It raises it. The Draft EIS should quantify projected new human ignitions attributable to new access. Second, the 2001 rule already permits cutting, sale, or removal of timber where it maintains or improves roadless characteristics, including for hazardous fuels reduction, and permits treatment in areas dominated by species that were uncharacteristic before European settlement. If wildfire is the concern, fund treatment in the wildland-urban interface, where the homes are. Do not use fire as a justification to construct new roads throughout the 45 million acres of roadless designated forests. I am not opposed to well maintained roads through National Forests, I am opposed to new roads. ask the Department to withdraw the proposed rescission and retain the 2001 Roadless Area Conservation Rule. Use your power to protect our wild spaces.

I recreate frequently on roadless areas of the very nearby San Juan National Forest. I am not alone in this sentiment, please keep the roadless area law intact so that future generations will have the same opportunity as I've had. Once the areas have roads, they will never be the same; there's no going back !

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

I live in the backcountry of Colorado at 9k+ feet, completely surrounded by national forest land. This canyon, which is part of the larger San Juan National Forest, stretches almost 20 miles with free campsites, paid campsites, mining claims, historic relics, and private landowners scattered throughout. These are all connected by a single, county-maintained road that is not maintained in the winter months. Each year, visitors flood the canyon to recreate and enjoy the 11k foot peaks that hug the road on either side. Why am I describing this setting? Because each year those same visitors camp in the free and paid campgrounds but also set up illegal campsites throughout the undesignated wilderness. It is hard to go a mile from the established road in either direction and not find an illegal fire ring. There have been dozens of times in my 8 years here that our county and the Forest Service have been in stage 2 fire restrictions and I drive by someone with a bonfire. The fire risk here is severe, and that is become increasingly more common as the SW faces severe drought. The thought of visitors having access to more roads and more opportunities to start illegal fires, thus significantly increasing the risk of a catastrophic wildfire, is concerning. We know that wildfires are 4 times more likely to start near roads. This is a complex environment here in the canyon, and even lifelong residents are unfamiliar with the weather patterns, drought, fire risk, and other issues. The La Plata County Government, State Government, and local Forest Service team, along with various local non-profit organizations, are most knowledgeable about this area and the impact to the economy and safety to the community of major decisions such as the Roadless Rule. The decision to open access should be left to the local county and state government officials. Likewise, who will maintain these roads with a government that faces a $40T debt, skeleton federal government workforce, and already severely delayed and underfunded road maintenance? The number of visitors who get into trouble on the 4WD only roads in this area is staggering. Car and truck rollovers, unprepared motorists, stress on local tow companies who are uniquely prepared to pull out a truck from a degraded road--these are all common occurrences in SW Colorado and we are not equipped to deal with more. And finally, my water source is an 8 foot gallery well that runs off a spring. I'm approximately 5 miles from the headwaters, and there are thousands of residents downstream who depend on this water. What will broad and unregulated access to remote areas do to the volume and safety of our water? Many who recreate in this canyon pay no heed to backcountry, leave-no-trace rules. It's a common occurrence to find piles of human feces, trash, and other materials that seriously degrade the environment and threaten to contaminate our water supply. Please consider the unique characteristics of many of our national forest areas and do not rescind the roadless area conservation rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Challenging myself with survival in the wild is an instrumental part of my fulfilled life. I walk the wilderness to connect with my innermost human spirit, and God is with me. I have personally experienced the freedom of mind and faith that our American wilderness areas afford to any hiker, hunter, angler, sportsman, or salvation-seeker, and I return to these untrammeled places again and again: the Kilkenny and Presidential-Dry River Extension units of the White Mountain National Forest in New Hampshire, the 1,483,000-acre Bob Marshall Wilderness Complex in Montana, the Bridger-Teton National Forest in Wyoming, the Hermosa and West Needle units of the San Juan National Forest in Colorado, Casto Bluff in the Dixie National Forest in Utah, and the Salmon-Challis National Forest in Idaho. These are not abstractions. They are where I seek what footpaths have always made possible. The creation of a road where none has been needed before, where footpaths have always sufficed, would greatly diminish the legacy I wish to leave to my children and generations to come. I do not want to be among the last Americans to experience wilderness in all these unique areas of our great country. The White Mountain National Forest exists in part because of what happened when New England's mountains were clearcut, a history that moved Congress to pass the Weeks Act of 1911. Its 16 inventoried roadless areas total 240,669 acres and form the headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. Roads change what a watershed delivers downstream. The agency should explain to the communities drawing from these headwaters what standard it applied to their interest in this rescission. The Bridger-Teton contributes the western extension of the largest intact temperate ecosystem in the world with 1,417,499 acres of inventoried roadless land. The DEIS quotes the federal grizzly recovery plan: the 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. I ask the agency to explain, for the record, how it weighs that finding against the proposed rescission. The agency's own fire data does not support its direction. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis concedes that road access could increase the number and frequency of wildfires. The agency should quantify the expected increase in human-caused ignitions from new road access and weigh it honestly against the claimed reduction in wildfire hazard before proceeding. The regulatory flexibility analysis reaches its no-impact conclusion by spreading expenditure losses across every small firm in the sector nationally rather than assessing the outfitters and guides actually holding permits in the affected areas. Yet "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 agency should withdraw that certification and assess the impact on the small entities actually operating in these areas, not the national average. Finally, the agency both restricts and expands its own scope in the same document. "The proposed rule concedes that subsequent revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." That revision scenario, including any expansion of timber harvest area, must be analyzed as part of this action, not deferred. The agency should identify and weigh ALL reliance interests described in the comments it receives before it acts. I have worked alongside NFS crews to clear trails in the Bob Marshall Wilderness for better access by hikers and horseback riders, never for vehicles. And I have felt pride when making a new friend because I helped his or her passage on horseback through the Bob. I strongly advocate for a formal, affirmative policy for wilderness areas of "Keep it Wild". I strongly oppose removing the Roadless Rule and ask for the Forest Service to adopt a "no action alternative" to keep the Rule intact, as it was written in 2001. I urge you to conserve our nation's roadless forests and keep the Roadless Area Conservation Rule in place. Sincerely, David A. Carre Wayne, Pennsylvania

To the U.S. Forest Service, I, Kaden Little, am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user and advocate for our nation's public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. I frequently visit the San Juan National Forest. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Thank you for the opportunity to provide public comment. Sincerely, Kaden Little

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The San Juan National Forest is where I find solitude, peace, and myself. I hike and camp regularly in the San Juan and in the Weminuche Wilderness, and I go looking for birds of prey that circle the high country and alpine lakes. I photograph grand mosaics of mountains, rivers, trees, and everything between. The Hermosa roadless area, 141,383 acres inside the San Juan, and the Lizard Head roadless area, 5,261 acres also in the San Juan, are part of that landscape. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens what those places are and what they support, and I oppose it. The agency's own record documents what roads do to birds. 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 percent of species avoiding the noise entirely. The birds of prey I go looking for above the alpine lakes of the San Juan depend on the quiet and the intact habitat that roadless designation preserves. The agency has not explained how opening these areas to road construction squares with its own cited science. I ask that the agency address, in its final response, how the rescission is consistent with the bird abundance data its own DEIS presents. The proposal also invokes wildfire management as a justification, but the agency's own language cuts against that 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." That finding comes from the agency's own record, not from opponents of the proposal. The agency must explain on the record why the proposal departs from its own prior findings on fire occurrence in roadless areas, and must 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 no stronger. The DEIS acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those marginal gains, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The Forest Service already carries a $6.9 billion road maintenance backlog. The agency must reconcile the proposal with an economic analysis whose own range of outcomes includes significant net loss, and explain in plain terms how expanding a road system already in deficit is justified when the resource gains are, by the agency's own admission, fractions of national production. The regulatory flexibility analysis compounds this problem. 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 is reached by spreading costs across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the areas at issue. The agency should withdraw the certification and conduct an analysis focused on the small businesses operating in the potentially affected roadless areas, not on a national average that obscures the real distribution of harm. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is such an interest. My use of the Hermosa and Lizard Head areas, the birds I go looking for there, and the photographs I take of those landscapes all rest on the expectation that roadless protections remain in place. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. Sincerely, Alex Whittow Durango, Colorado

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting and fishing and climbing in Colorado's national forests are not abstractions to me. I grew up hunting with my father, and I feed my family with game meat. I am raising daughters who cherish wildlife, and who fish and backpack and climb. My father taught my daughters to fish the way he taught me. I have watched what roads do to fisheries: sediment, chemicals, and trash from nearby roads trash the water. I have been going to the Hermosa roadless area since 2008. It holds some of the largest trees in Colorado, and it survived the 416 fire remarkably well because of fire mitigation work conducted on foot and aerially. Roads would ruin its character and the clean and abundant water it provides as a major tributary to the Animas River. That is the country I am defending here, and the country this rescission puts at risk. The agency's own record makes the wildfire argument for rescission hard to square with the data. 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." Hermosa's survival of the 416 fire was not an accident, and the agency's own ignition data confirm that roads raise fire risk rather than reduce it. I ask that the agency explain, drawing on the specific findings in DEIS Table 21, how the proposal's wildfire rationale can be reconciled with these findings from its own draft environmental impact statement. The economic case for rescission is equally difficult to defend on the record. The agency itself has found that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that baseline, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of between $5.2 and $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from negative $92 million to positive $199 million. A range that spans nearly $300 million and cannot establish a net benefit does not justify adding to a road maintenance backlog already sitting at $6.9 billion. The agency must reconcile that internal contradiction before proceeding. The legal history here is not a minor footnote. The proposal argues that state-by-state approaches can substitute for one national rule, but the record shows how that played out before. The agency previously described its own dissatisfaction with the national rule and "highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.'" That argument did not survive judicial review the last time the agency pursued it. The agency's own prior findings acknowledge that incremental local decisions can erode nationally significant roadless values in ways a state process cannot prevent. The agency must explain how this proposal avoids the specific deficiencies identified by the Ninth Circuit when the national rule was last replaced with a state-by-state framework. On authority, the agency argues the 2001 rule exceeded its statutory power. The courts that examined that question held otherwise. The Tenth Circuit stated: "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 found the rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and found it did not create de facto wilderness. The agency must explain in its final response the legal basis for any position that conflicts with that holding. Colorado holds 326 inventoried roadless areas totaling 4,407,277 acres. Across the Rocky Mountain region, 325 municipal water intakes sit in watersheds containing affected roadless areas. Hermosa, the Piedra SMU, and the San Miguel areas in the San Juan National Forest represent the kind of country, the fisheries, the wildlife habitat, the clean water, that the 2001 rule was built to protect. The Hermosa drainage is already providing water to the Animas River system, and I have watched it do so since 2008. The agency has not shown that rescission improves on that outcome by any measure its own record supports. Sincerely, Kevin Heiner Durango, CO

Re: Comment in Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule Dear Director, I am writing in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule ("Roadless Rule") and the accompanying Draft Environmental Impact Statement. I am a forest entomologist and Assistant Teaching Professor of Forestry at Northern Arizona University, where I have spent over fifteen years studying arthropod and plant communities across the Colorado Plateau, including field courses that bring students into roadless portions of the Coconino and Kaibab National Forests. I also conduct personal research and recreation in the roadless backcountry of the San Juan National Forest and the Dolores River canyon country of southwestern Colorado. I ask the Forest Service to withdraw this proposal and retain the Roadless Rule in its entirety. These lands are irreplaceable, and there are vanishingly few of them left. The National Forest System already contains over 370,000 miles of roads — roughly eight times the length of the entire U.S. Interstate Highway System. Despite this, only about 5% of the contiguous United States remains free of roads as inventoried roadless area or designated wilderness; the most remote point in the lower 48 states, in Yellowstone, is just 21.5 miles from a road. On the Coconino National Forest, roadless areas cover only about 10% of the forest; on the Kaibab, roughly 40%. These are the last remnants of an increasingly rare condition on the American landscape, and once roaded, they do not return within any timeframe that matters to the wildlife, watersheds, or people who depend on them. Roadless areas are essential wildlife habitat, and that matters directly to hunters and anglers. Elk habitat effectiveness declines roughly 25% once road density reaches one mile per square mile, and roughly 50% at two miles per square mile — thresholds already exceeded across much of the roaded National Forest System. Roadless areas provide the security cover, connectivity, and undisturbed watersheds that big game and native trout depend on. I hunt and fish these landscapes myself, and that experience is inseparable from their roadless character. These lands also hold the increasingly rare experience of genuine solitude — fifteen years ago I proposed to my wife on the banks of the Dolores River, miles from the nearest road, in a place defined by its silence. Roadless National Forest lands are among the last places left for that kind of experience. The agency's wildfire rationale is contradicted by the evidence, including my own field of research. A case-control study of ignitions in the eastern Cascades (Narayanaraj & Wimberly, 2012, Applied Geography) found human-caused ignitions strongly concentrated near roads and in high-road-density areas, while the largest, most destructive fires occurred disproportionately in remote, roadless terrain — driven by fuel continuity and weather, not road access. National-scale data reach the same conclusion: wildfires are roughly four times more likely to start in roaded areas than roadless tracts, and about 90% of ignitions occur within half a mile of a road. Expanding roads into roadless areas would predictably increase ignition risk in the hardest, most expensive places to defend, while doing little for the weather- and fuel-driven fires that account for most burned acreage. If community wildfire risk is the true concern, the evidence points to targeted fuel treatments near the wildland-urban interface — already permitted under the existing rule — not road-building across 44.7 million acres of protected forest. The proposal also ignores fiscal reality: the Forest Service already carries an $8.5 billion-plus deferred maintenance backlog on its existing road network, and building new roads into remote terrain would only deepen it. The Roadless Rule was built on one of the most extensively documented rulemaking records in Forest Service history and has functioned successfully for a quarter century to protect drinking water for 60 million Americans, wildlife habitat, old-growth forest, and recreation across 58.5 million acres in 39 states. As a forest scientist, educator, hunter, angler, and someone who has built some of the most meaningful moments of my life in roadless country, I urge the Forest Service to withdraw this proposal and retain the 2001 Roadless Area Conservation Rule in full. Sincerely, Dr. Derek Uhey Assistant Teaching Professor of Forestry, Northern Arizona University Coconino County, Arizona

I am writing to strongly oppose the proposal to fully or partially rescind the 2001 Roadless Area Conservation As a frequent hiker, cyclist, camper, these undeveloped lands are directly tied to my lifestyle and community. I frequently recreate in the San Juan national forest, and I rely on these areas for clean drinking water, solitude, and intact fish and wildlife habitat. Rescinding these federal protections undermines decades of durable conservation. The proposal to allow commercial logging and road construction ignoring the existing multi-billion-dollar road maintenance backlog is fiscally irresponsible. Additionally, expanding motorized networks into these zones creates a proven vector for human-caused wildfire ignitions, rather than mitigating fire risks. The current 2001 framework successfully balances forest health with ecosystem preservation. I urge the Forest Service to keep the national Roadless Rule fully intact.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Continental Divide Trail through southwest Colorado is where I backpack, and I want that country preserved as natural and wild. The Hermosa area within the San Juan National Forest, part of the 4,407,277 acres held in Colorado's 326 inventoried roadless areas, represents exactly what the 2001 Roadless Area Conservation Rule was built to protect. I oppose the proposed rescission of that rule and ask the agency to address the following points in its record. The proposed rule carries a certification that the action will have no significant impact on small entities. That certification cannot be squared with what the agency's own analysis shows. "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 regulatory flexibility analysis reaches its no-impact conclusion by distributing a $9 million annual expenditure loss across every small firm in the sector at the national level, not by examining the outfitters and guides who actually hold permits in the specific roadless areas at issue. The analysis itself concedes that some firms may lose those receipts. That is not an assessment of impact on small entities; it is an averaging exercise that obscures real harm. I ask that the agency withdraw the certification and conduct a genuine evaluation of the small businesses actually operating in the potentially affected roadless areas. Backpackers, recreationists and communities across the country have ordered their choices around the protections the 2001 rule put in place. The agency invites exactly that kind of testimony: The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. When an agency changes course, it is obligated to identify and account for the reliance its prior policy created. This comment is one such interest. Having solicited reliance interests from the public, the agency must then weigh them. I ask that the record show how the agency evaluated the reliance interests described in the comments it received, including this one. The agency's own fire data presents a serious problem for the proposal's justification. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis itself acknowledges that road access could increase the number and frequency of wildfires. Yet the proposal is in part justified on wildfire hazard reduction grounds. The agency cannot simultaneously hold that roads increase human-caused ignitions and that opening roadless areas to road construction will reduce fire risk without quantifying how those two conclusions interact. The agency must calculate the expected increase in human-caused ignitions that would follow from new road access and set that figure alongside the claimed reduction in wildfire hazard before this record is closed. The fragmentation finding embedded in the DEIS raises a concern the analysis never resolves. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and then stops there. No projection of what that reduction means across the 40.1 million acres of potentially affected environment follows. A number cited but never applied to the landscape it describes is not analysis; it is decoration. Hermosa and every other inventoried roadless area that could be affected deserve an honest accounting of what that fragmentation range, applied to 40.1 million acres, would mean for the wildlife and watersheds within them. The agency should apply that cited range to the full potentially affected acreage and show its work. Colorado's roadless areas, including Hermosa, are governed by the 2012 Colorado Roadless Rule, which the current proposal leaves in place. But the downstream effects of a national rescission, including any shift in administrative posture toward roadless protection generally, remain unaddressed for Colorado specifically. I ask the agency to clarify on the record what, if anything, changes for Colorado roadless areas in management practice or legal standing if the 2001 rule is rescinded, so that Colorado commenters can evaluate the real stakes of this proposal for their landscapes. Sincerely, [Loyde Carpenter ] [Palm Bay, FL]

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

Hi I would like the USFS to keep the Roadless Rule in place as it has been for the past 25 years. I commented in favor of the rule in both 1999 and 2000 and have been very pleased with the use of the rule and that no new roads have been built. Roadless are important for keeping watersheds clean, places for trees to grow and absorb carbon dioxide so they act as carbon sink, and keeping noise out of these deeper forests in excellent for wildlife. So please don't change the roadless rule. This has been great and will continue to be great for many generations to come. Thank you Sam Carter Dolores, CO San Juan National Forest

I have 17 years of land management experience with the US Forest Service and 21 years with the US Fish and Wildlife Service. I understand first-hand how these lands are critical to water and watershed protection, wildlife and fisheries habitat, reduced risk of wildfires, and world-class recreation. I live adjacent to the San Juan National Forest in southwest CO, and allowing impacts to these lands would be devastating. A study done in Colorado supports all my concerns. I include it here as part of my comments. https://roadless.org/resources/colorado-wildlands-report.pdf Rescinding the Roadless Area Conservation Rule (the Rule) threatens all of these benefits and gives control of these roadless public lands to greedy extractive industries and administration cronies. Road construction is not one threat — it is the enabling condition for most of the major threats that imperiled species and ecosystems face on National Forest lands. The Inventoried Roadless Areas exist in their current ecological condition because roads were never built. Rescinding the Roadless Rule activates a cascade of harm documented by NatureServe, the IUCN, and the U.S. Fish & Wildlife Service. I am also concerned with NEPA adequacy concerning this proposal, including the cumulative-effects analysis, range of alternatives, and other procedural requirements that a Draft EIS must satisfy. I will highlight my concern with a narrowly drawn purpose and need statement that forecloses meaningful alternative analysis. The Purpose and Need statement frames the rescission's justification exclusively around the Department's stated belief that "increased management flexibility in the administration of these lands is needed to better meet the multiple-use mission" (Purpose and Need for Action, pp. 18-19), without articulating any criteria against which intermediate alternatives—short of full nationwide rescission—could be meaningfully measured. This framing risks predetermining the outcome by defining the need in terms that only wholesale rescission can satisfy, foreclosing genuine consideration of a reasonable range of alternatives as NEPA requires under 42 U.S.C. § 4332(2)(C). As the Seventh Circuit recognized in the persuasive, out-of-circuit decision Simmons v. U.S. Army Corps of Engineers, 120 F.3d 664 (7th Cir. 1997), a narrowly drawn purpose and need statement that forecloses a reasonable range of alternatives violates NEPA's core mandate. I ask the agency to broaden its purpose and need framing with articulable criteria that permit genuine evaluation of intermediate management-flexibility options. The Purpose and Need section frames rescission almost entirely around administrative flexibility while giving only passing acknowledgment to the 2001 Rule's protective function. The DEIS itself states that the 2001 Rule was "intended to provide lasting protection for inventoried roadless areas," then pivots directly to the assertion that "increased management flexibility... is needed to better meet the multiple-use mission" (Purpose and Need for Action, pp. 18-19), without weighing that flexibility against the ecological values the Rule was designed to protect. Independent research found that 57% of wildlife species of conservation concern have suitable habitat in inventoried roadless areas, and that these areas often protect watersheds supplying drinking water to hundreds of thousands of people. The document does not address whether the agency considered this evidence or why it was rejected. NEPA requires forthright disclosure of trade-offs under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989) and 42 U.S.C. § 4332(2)(C). I request a revised, balanced Purpose and Need section addressing these values. I implore you to stop this action of rescinding the Roadless Area Conservation Rule. Nancy McGarigal Dolores, CO

Dear Chief Tom Schultz: As a former wildland firefighter and current municipal firefighter, my objection to the rescission is operational, not ideological — the rule has been good for fire management, and the notice doesn't show otherwise. I have been recreating and working in National Forests since before I could walk. Professionally, I spent 3 seasons as a commercial backpacking guide in the San Juan National Forest in southern Colorado, and frequently was adjusting trips to avoid wildfires and smoke. Afterward, I switched to chasing wildfire with the Forest Service as a wildland firefighter in the Columbia River Gorge Nation Scenic Area in region 6. I've used roads, trails and rivers to access wildfires, both human and lightning caused. I've personally held responsibility for starting a new spot fire on the side of a road with the hot tailpipe of my type 6 engine while actively fighting a wildfire. The lucky ending of that story is that an engine staffed with firefighters is equipped to put that fire out quickly. The same cannot be said of most other vehicles. I'm now quite conscious of not parking or idling in dry grass. J.K. Balch, B.A. Bradley, J.T. Abatzoglou, et al. in a review of human caused vs lighting caused fires from 1912 to 2012 found that "the human-caused fire season was three times longer than the lightning-caused fire season and added an average of 40,000 wildfires per year across the United States." This is not just a huge ecological impact, it a massive economic impact. There is no valid argument the rescinding the roadless rule makes economic sense for Americans. A roadless area that I have fought fire in and frequently recreate in is the Mt. Hood Additions in the Mt. Hood National Forest, Oregon. Rescinding the Roadless Rule would open the Mt. Hood Additions, Mt. Hood National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Olden JD, Postel SL, Dombeck MP, et al. (2026) call roadless areas "essential for sustaining ecosystem services, supporting human well-being, and advancing broader conservation and resilience goals under increasing climatic and land-use pressures". This is especially clear in the Mt. Hood NF, where the dwindling salmon population is a frequent topic of concern for recreation, conservation and economic reasons. To those of us familiar with forests, wildfire, firefighting and the science around all three, it is undebatable that the Roadless Rule is essential for healthy forests, fire and communities. I don't need Aplet, G.H., Hartger, P. & Dietz, M.S. to tell me that the bulk of wildfires start within 50 m of a road. I've seen it, fought them, and unfortunately been a part of that statistic. I don't need Victoria J., Bennett to explain to me how roads fragment ecosystems and thus harm forest health, water and air quality, and animal populations, I've seen and experienced it. And when Zhou, D., Xiao, J., Liu, S. et al. note that “Within 1 km of roads, forests show 18.6% lower forest cover, 2.7 m shorter canopy height" I know that directly translates to increased fire risk due to reduced moisture retention and increased sun exposure in the understory. I've seen this as I've "slung the weather" with a sling psychrometer to measure temperature and relative humidity as a lookout on a fire. What is obvious even to the casual observer, and quantified in numerous studies, is that roadless areas benefit us in countless ways including by supporting clean air and water, biodiversity, and more natural fire patterns. This is not just a conservation or fire issue, it is a community health issue, a cultural issue, and economic issue. The Department should reject this proposal and maintain the protections the Roadless Rule has provided since 2001. Yours sincerely, Greta Smith CommentID: RLC-20260901-KXNZRC