Read the comments.

I am opposed to the USDA revocation of the roadless rule. On page 10 of the EIS you state: “The Department is proposing this rule rescission to reduce regulatory burden and return land management decision-making for inventoried roadless areas to local Forest Service officials. Subsequent text continues in the same vein. The remainder of the EIS does not present any specific case evidence that there is a need for these actions. The intent of this rulemaking therefore is reflective of a political aspiration or ideology. Thus the entire basis of the rule is unsupported by a real need and the revocation should be rejected. Construction of additional roads in roadless areas will not decrease wildfires. Wildfires are caused by past management practices, extreme temperature, fuel buildup, nightime temperatures, wind, and the ability to respond to fires, which has been severely curtailed by the current administration, specifically within the Forest Service. “With increased road access, initial attack success rates would be expected to increase. Additional roads would provide safer, more effective, and more efficient containment opportunities, potentially reducing fire sizes and durations. Page 103. Not mentioned is that increased road access the opportunity for wildfires will increase as it will make the roadless areas more open to human activity. Scientific American states that the majority of wildfires that threaten communities are started by human activities. Of major concern in fire fighting is the reduction in numbers of federal firefighters. The ability of firefighters to respond to fires is a key component in minimizing impacts. Where hiring rebounded from the administration cuts of 2025, it was in non-permanent employees, thus a lack of long-term readiness (https://www.federalhiringdata.com/articles/wildland-firefighter-workforce-2026). The Forest Service does not have sufficient resources to maintain their existing road network. The EIS states that annual maintenance need for Forest Service roads is 1.6 billion and their appropriation was 270 million in 2023. I personally experienced the very poor quality of passenger car roads in the Santa Fe National Forest, where turning back was the only option. Creating more roads when the existing roads cannot be maintained is a unsupportable policy. The economic impact of recreation is on a par with the expected increase in timber sales and is a major component of local economies and small businesses. Repealing the roadless rule would disproportionately impact these citizens in favor of especially timber interests. Further the non-commoodity values listed on pages 216 and 225 are not represented in economic calculations. These impacts have an economic impact (i.e. poorer air and water quality) and the diminshment of recreational opportunities for example. This disregard is one more reason I oppose the revocation of the roadless rule.

Sarah Hyden The Forest Advocate Santa Fe, NM Thank you for the opportunity to submit comments on this vital issue. The Forest Advocate has approximately 1,800 members. This organization is dedicated to protection and preservation of the Santa Fe National Forest, and all forests. We are submitting the attached comments from The Conservation Biology Institute. Please regard them as comments from The Forest Advocate. Thank you, Sarah Hyden Director The Forest Advocate.

Our family's livelihood is earned directly through permitted use of our Wilderness Area, in Santa Fe National Forest. If motorized vehicles were allowed into this area, it would destroy our business, as well as others, in this rural area. Not to mention the irreparable damage to the ecology of the area, and the destruction of our local wilderness-based culture. Do not rescind the roadless act.

Hi, I am writing to register my opposition to rescinding the 2001 Roadless Rule. Some of the most wonderful places in our great United States of America are places that have not yet had roads built into them. They are wonderful refuges for wildlife. One of my fondest memories of a roadless area was an area in the Santa Fe National Forest. In 2016, I took my 11 year old son on a week-long backpacking trip in the Santa Fe National Forest. We had the wonderful experience of see a large male Black Bear in this area on the morning of our second day. To this day, that trip and that experience with the Black Bear remain my son's (who is now an adult) favorite trip into nature. Without this Roadless Rule, our nation's young people will not have as many opportunities to experience wild nature -- which is an important part of becoming a well-rounded human being. We don't have many wild places left in our country, so please remember the advice of President Theodore Roosevelt: "The nation behaves well if it treats its natural resources as assets which it must turn over to the next generation increased and not impaired in value ." Please keep the 2001 Roadless Rule in effect. Thank you! Sincerely, Bryan K. Walton

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Quiet, unpaved wilderness is what I live on Earth for. It is central to me spiritually, emotionally, and physically, and I spend a good amount of my income to reach it. The Santa Fe National Forest, the Boundary Waters, the Gila Wilderness, the Grand Canyon: the list goes on. Paddling through the Boundary Waters is an unmatched experience. People fly across oceans to do it, and I cross miles, too. I oppose the rescission of the 2001 Roadless Area Conservation Rule because what I depend on, and what the land itself depends on, is directly at risk. Public land should be for the Earth. It should be for nature, for lichen and trees and wildlife that grow there. That is not a sentimental position; it is a recognition that the value these places hold cannot be recovered once roads fragment them. The rule's rescission would erase that recognition without adequately answering the costs. The agency's justification rests partly on permitting and administrative burden, but the rule as written already contains the flexibility it claims is missing. The agency's own text states that 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)." If the existing exceptions for public health, safety, mineral leases, and community wildfire protection already accommodate the situations the agency cites, the agency has not explained what specific burdens remain. I ask that the agency identify, by category and quantity on the record, which burdens are not already resolved by those existing provisions. On water, the Southwest's situation makes this rescission especially reckless. Nevada alone holds 316 inventoried roadless areas totaling 3,186,206 acres, and across the Intermountain region 1,466 municipal water intakes sit in watersheds containing affected roadless areas. We are already facing increasing drought pressures, and all science projects that we will continue to lose water. Nevada, California, and Arizona have recently lost access to Colorado River allocations. What are the long-term economic costs of impairing crucial watersheds against the short-term benefits of new roads? What are the financial projections for states already confronting diminished water supplies, and how does the agency expect those states to protect water quality at the source without the protections this rule provides? The agency must answer those questions in its final analysis. A close friend of mine is a firefighter who has risked their life to save communities from flames started along roads, with long-term health consequences from that work. I myself have had my job and life disrupted by having to flee from wildfire. The agency's own data make the connection explicit: "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." Given that the effects analysis concedes road access could increase the number and frequency of wildfires, I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it transparently against the claimed reduction in wildfire hazard, rather than leaving that calculation unresolved.

Dear USDA Secretary Rollins, I strongly urge you to keep the 2001 Roadless Rule in tact, protecting 45 million acres of National Forest Service lands. This rule is incredible important for a variety of reasons. To me, one of the most important reasons is wildfire mitigation. Wildfires are four times more likely to happen in roaded forests and often happen within a half mile of the road. We should be focused on stopping wildfires before they even start, rather than having to get into the forest to put the fires out. Another reason to protect these areas is water quality protection. Our waters are vital for the health and well being of nearby communities and the plants and animals who call those places home. More roads will increase runoff of harmful chemicals from cars to these water systems, as well as increase the turbidity from construction. As a conservationist, I've led hikes in the Santa Fe National Forest and the Lincoln National Forests in New Mexico in Inventoried Roadless Areas and have seen how beautiful these areas are and shared that beauty with other folks from around New Mexico. Please keep the Roadless Rule in place for generations to come. Thank you for your time. Sincerely, Shelby Bazan, New Mexico

Hiking at least weekly through the Pecos Wilderness, the Santa Fe National Forest, and the Carson and Cibola forests, I know what these landscapes are. In a 3 hour drive you can hit five different kinds of rock in the National Forests of New Mexico, an incredible resource and not something you get in other places. I have been an outdoor guide for over 15 years. Public land, wild land, and limited access to this land is essential not only for my work, but for the health of humanity. What makes me happy out there is seeing wild things, plants, animals, fungi, getting to be wild, and not crowded or polluted. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens exactly that, and I oppose it without reservation. The agency claims that recreation losses from this rescission would be modest. But its own document states, in the Economic Benefits from Recreation in Roadless Area Forests section, that "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally." That figure is placed against roadless recreation benefits of upwards of $1.5 billion, and the same section acknowledges that the magnitude of losses is unknown. Roads and shifts in recreation settings accumulate over decades, and a single-year 1 percent cap does not capture that reality. The agency should estimate cumulative recreation losses over 20 years as roads are built and settings change, and compare them with projected timber revenue, and it should answer that question plainly. The document also claims, in the Rationale for the Proposed Rule section, that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." But the document also cites research finding that the rule did not meaningfully constrain fuel treatments as a share of forested land, and it acknowledges that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. Those two positions cannot simply sit side by side without explanation. I am asking the agency to reconcile the forest health rationale with its own findings on fuel treatment constraints and insect risk in roadless areas. The proposed action would open timberland where the agency's own data, cited in the Implications for Forest Vegetation, Health, and Carbon section, show that "approximately 11-16 percent is old-growth forest, 54-63 percent is mature forest, and 26-31 percent is young forest." Old and mature stands together make up the large majority of the land most likely to be logged. The Gila, Lincoln, Carson, Cibola and Santa Fe National Forests of New Mexico hold some of this country. These stands are irreplaceable. The document identifies no old-growth-specific safeguards beyond general land management plan compliance before harvest could proceed. The agency must separately disclose and analyze protections specific to old-growth before any harvest is authorized in this land base. Our forests, as they are, are the most valuable resource in America. They are absolutely irreplicable. The decision before this agency is not a minor administrative adjustment. It is a choice that will shape these lands for every generation that follows. I expect the agency to answer each of these points before it proceeds.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The children I work with in my forest school program are under eight years old. What I bring them to, every time, is the national forest near where I live. Birds, deer, fox, coyotes: these are not abstractions for them. They are the lesson. When this administration proposes to rescind the 2001 Roadless Area Conservation Rule entirely, it is proposing to dismantle the protection that makes that lesson possible. I have backpacked in the Pecos, in the Carson National Forest, for over a decade and a half. Losing that would be painful. That is the only word I have for it, and I think it is the right one. Rio Medio, in the Santa Fe National Forest, is so incredibly special, and losing it would impact the watershed. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres. These are not marginal scraps. They are the water supply and the wildlife corridor and the quiet that makes birds findable and children teachable. On fire, the agency's own record undermines its own justification. The DEIS states directly: "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." The proposal cites fuels management as a rationale for rescission. Those two positions cannot both be true. I ask the agency to explain the departure from its own prior findings and to reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The birds I look for with children in these forests depend on exactly the conditions the rule protects. 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. For deer, the agency's own record cites research finding that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed, and the Tribal Summary Impact Statement credits the rule's protection with deer population recovery by preserving old-growth winter shelter. These are not outside critiques. These are the agency's own citations. I want to know how the agency squares opening these areas to roads with its own documented findings on the wildlife consequences of doing so. The economic case for rescission does not hold up either. The record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million. Across the Southwestern region alone, which includes New Mexico, 739 municipal water intakes sit in watersheds containing affected roadless areas. The agency must reconcile this proposal with an analysis that cannot establish a net benefit, and explain how it justifies expanding a road system already carrying a $6.9 billion maintenance backlog. On the state-by-state approach the proposal advances: the record itself records the agency's prior rejection of the rule's approach in favor of local flexibility, citing "its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That approach was litigated and lost. The agency must address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and explain how this proposal avoids the deficiencies identified the last time the national rule was replaced with a state-by-state system. Finally, on statutory authority: the Tenth Circuit already reviewed that question and held that the 2001 rule was within the authority Congress granted. The court 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." The agency must address that holding, including the court's conclusions regarding the Organic Act and the Multiple-Use Sustained-Yield Act, and explain the basis for any contrary legal position. I oppose this rescission. The places it would open are the places I work in and love. The agency's own record does not support this action. Sincerely, Resident of Santa Fe, NM

The true value of our natural resources in the United States of America cannot be fully understood and appreciated unless one has experienced these personally. Land, clean air, healthy trees, adequate and clean water, and wildlife that survive and thrive in our national forests deserve to be protected. Over past decades I have hiked in, boated in, skied, and camped in a number of our spectacular national forests: the Olympic National Forest, Mount Baker Snoqualmie NF, Okanagon-Wenatchee NF, the Cherokee NF in my native state, the Deschutes NF, the Finger Lakes NF, the Gifford Pinchot NF, the Huron-Manistee NF, the Idaho Panhandle NF, the Malheur NF, Mount Hood NF, the Pisgah NF, the Santa Fe NF, the Tongass NF, the Tonto NF, the Umatilla NF, the Umpqua NF, the Wallowa-Whitman NF, and the Willamette NF. In 2001 when the Roadless Rule was enacted, it allowed the NFS get somewhat caught up on maintenance of the 44.7 million acres of Inventoried Roadless Areas (IRAs). The 9.3 million acres of IRAs in the Tongass National Forest have also been better protected than prior to the RR. The claims being made in the Proposed Rule do not « hold water. » It was local control (one of the purported justifications for rescinding the 2001 RR) that led to enormous harm in the Wolverine Fire of 2015 in Washington state. Local pressure by regional fire departments persuaded the Director of the Firefighting Operations, a staffer brought up from the Tonto NF, ordered a CPL (Community Protection Line) that ended up a 50-mile long, 300-foot wide CPL and cut 40% of the critical habitat for the endangered Northern Spotted Owl. Over 930 log trucks hauled out logs, with one tree being so large that it was the only tree on one of the trucks. In my view, it was criminal to do that much damage. The scientist on the Oka-Wen NF tried to persuade the fire director that the fire was not heading in the direction of the CPL cuts. « Managers continued logging even after weather conditions turned rainy and cool, and objections were raised by their own staff, who saw no emergency, internal records and emails to The Seattle Times by US Forest Service showed. The fire never came anywhere near. » (Lawsuit over firelines to curb forest firefighting tactics, August 22, 2016) Another purported reason given for the Proposed RR Rescission is to reduce wildfire. This is not logical or rational. By allowing access to more roads in the roadless areas, there would be a greatly increased likelihood of experiencing human and vehicle-related forest fires. Strong scientific studies support this and argue strongly against opening up our roadless areas to more traffic for logging or other forest treatments. In fact, fires are four times more likely to occur near roads than in roadless (DEIS, p. 87) Good water quality is also more available in IRAs because of limited disturbance. « Retaining the RR ‘provides the greatest protection of water quality’ for municipal water supplies. » (DEIS, p. 122) For these reasons, and in the hope that science and good evidence about the superb values of Roadless Areas in our USFS will prevail, I strongly oppose the Proposed Rescission of the 2001 Roadless Rule. I would appreciate your serious consideration of my comments. Another

I live in New Mexico and I am 10 years old. I spend a lot of time in national forests. My favorite place to be is on a rock in a forest as the sun comes up, watching the grass steaming. I am attaching a picture of me and my small cousin backpacking in the Santa Fe National Forest two weeks ago. I am commenting to oppose the removal of the Roadless Rule. I think the Roadless Rule should remain because the animals need a home where they can stay safe, that way humans won’t disturb them. There will be more of a fire risk if we make roads than if we don’t because humans start wildfires. There are already ways to get out into places where the Roadless Rule applies if someone wants to enjoy nature. The Forest Service already has the ability to make roads in emergencies such as wildfires. I recommend that temporary roads for wildfire suppression be closed after use. I think National Forests are beautiful and it is a terrible idea to remove the Roadless Rule because it will not improve the wildfire situation.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing about the Santa Fe National Forest in New Mexico, and I am asking this agency to reject the proposed rescission of the 2001 Roadless Area Conservation Rule. Black Canyon and Little Tesuque have been part of my life for many years. I have hiked both, gone on birding expeditions through them, and joined small groups studying the trees. They are dear to my heart, and I know I am not the only one who feels this way. The Santa Fe NF contains roadless areas I know well, among them Black Canyon at 1,922 acres, Little Tesuque at 815 acres, Pacheco Canyon at 1,012 acres, and the Juan de Gabaldon Grant at 8,023 acres in the high terrain of the Sangre de Cristo Mountains. Pacheco Canyon is a gorgeous multi-use trail I have hiked with friends and where I have seen others on bikes and horseback. The Juan de Gabaldon Grant sits close to Tesuque Pueblo, a community I have visited, and it lies within a watershed that must be protected from road development and what that would bring. Little Tesuque is a shaded, picturesque creek trail used by many locals in the Santa Fe area, popular for birding, easy hiking, biking, and running. Preserving it for that recreational use is essential to the well-being of people living here. Black Canyon provides locals and visitors a place to camp, hike, bird, and enjoy the ponderosas, aspens, and white pine. The birding I do in these places is directly relevant to this proposal. The agency's own record states 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 DEIS cites Kroeger et al. 2022, McClure et al. 2013, and Ware et al. in support of these findings. Every road built into Black Canyon or Little Tesuque would fragment exactly the quiet, intact habitat that makes these areas worth photographing and worth visiting. I ask the agency to explain, specifically and in response to this comment, how those findings about bird abundance and species avoidance are reconciled with a proposal that opens these areas to road construction. The agency's own findings on fire make the rescission harder, not easier, to defend. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If fire risk is the justification, the data point the other direction. I ask that the agency reconcile this proposal with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain what analysis overrides its own prior findings. Nichols Reservoir is a key municipal water storage area in the Santa Fe Municipal watershed. Water is critical in the high desert foothills of the Sangre de Cristo Mountains. The agency's record shows that across the Southwestern region, which includes New Mexico, 739 municipal water intakes sit in watersheds containing affected roadless areas. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres. Roads bring sedimentation, erosion, and contamination risk to source water. The agency must address the drinking water consequences for communities like Santa Fe before this rescission can move forward. The economic case is also unsupported by the agency's own numbers. The DEIS 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." Against that marginal production gain, the agency's Cost Benefit Analysis projects recreation losses of at least $6.1 million a year and a net present value ranging widely, while the road maintenance backlog already stands at $6.9 billion. The agency must explain on the record how an action whose own analysis cannot establish a net benefit justifies further expanding that road system. Finally, the rule as written already provides flexibility. It states that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency has not identified which specific burdens fall outside those exceptions. It should do so, with specifics, not generalities. These are real places with real communities, real water supplies, and real wildlife. The agency should withdraw the proposed rescission. Sincerely, Karen Weber Santa Fe, New Mexico

To the U.S. Department of Agriculture: I am writing as a hiker, a nature lover and a concerned citizen living in Santa Fe, New Mexico. I am in opposition to rescission of the Roadless Rule. New Mexico has 1.6 million acres of inventoried roadless areas. In my community of Santa Fe, there are 241,910 acres of pristine wilderness and backcountry within the Santa Fe National Forest protected by the Roadless Rule. When I tell friends and family why I love living in Santa Fe, it is the natural beauty, and ready access to the surrounding mountains, forests, streams and that is wilderness at the top of my list. Being in nature is one of life's great ways to destress and heal, and we are losing these areas too quickly. The Santa Fe National Forest is exquisite, and once gone, can never be replaced. The Roadless Rule crucial to protecting these natural spaces. The above issues have particular immediacy in Santa Fe and Northern New Mexico. We have endured many years of drought, which we have witnessed exacerbate many fold in this past year alone, with extreme temperatures and little rain. Wilderness areas and forests help to hold and store water from rain and snow pack, provide clean runoff for drinking water, and help maintain our critical reservoirs and ancient acequia irrigation systems. We cannot afford to put our water supply at risk. While I am expressing my personal concern for my home in Northern New Mexico, such fragile protected ecosystems exist in thousands of locations throughout the country. Each ecosystem has unique and important value. I am deeply concerned that the implications of opening up these spaces to roads, vehicle traffic, mining, logging and other activities has not been adequately studied for each and every area affected, and that a rush to broadly repeal a rule that has provided protections for 25 years should not be done in haste. Any arguments made to the contrary, such as improving forest management or reducing wildfire risk, are specious and are rooted not in data but ideology. I implore the US Department of Agriculture and the Trump Administration to take a step back, and consider the impact of rescission of the Roadless Rule on the natural areas and wildlife so many of us love, and the watersheds we critically need. With thanks, CommentID: RLC-20260921-L6K2WW

We have about 241,000 inventoried roadless acres in our Santa Fe National Forest. Putting in more roads on top of the existing fire breaks and access roads for thinning and prescribed burns would compromise the watershed and damage our water supply. The administration that is proposing to rescind the roadless rule apparently has little understanding of the importance of keeping large sections of forest and watershed untouched and functioning as an ecosystem that both attracts greater rain and snowfall as well as collects it and naturally filters. Without roadless areas staying intact and large, we will damage our water supply and put our forests at risk at drying out and being more fire prone. One of the stated goals of this rescision is to "give local communities "greater control." Good. Local communities will tell this administration exactly why the roadless rule was put into place and just why it is vitally important to keep it as it is. Also roads are a major wildfire contributor. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

I am submitting the following comments on the proposed rule that would rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule) on National Forest System lands, including the Tongass National Forest. Reference RIN 0596–AD66, published in the Federal Register August 20, 2026. I support the no action alternative and believe that the current administration’s reasons for eliminating the Roadless rule do not support elimination of the rule. In addition, the Forest Service has not allowed adequate time for review and comment on this proposed rule. My family and I have resided within a watershed arising in the Santa Fe National Forest, within six miles of the Forest boundary, for over 40 years. The water supply of the aquifer where our domestic well is located originates on the lands of the Santa Fe National Forest. We are directly impacted by the effects of Forest land management activities. 1.Any Forest land use activity must be in accordance with intention of the Forest Service Organic Administration Act of 1897, which requires the protection of the forests and the water supply originating on the Forest lands, including the lands upstream of our well. The Draft Environmental Impact Statement’s discussion of the Organic Act focuses on the impact of road construction for the principal purposes of mineral resource extraction and logging while the protection of water supply originating on Forest lands is treated as a secondary purpose. The roadless rule should not be rescinded unless it can be shown that the production of good quality water is protected. 2.The proposed rule seeks to rely upon the flexibility of the local land management planning process, through local decision making and planning without restrictive and unnecessary national prohibitions, according to the Federal Register Notice. Will the current administration commit to ensuring that a fully staffed workforce will be available to support this local decision-making process? Without that assurance, the planning process may fail. The elimination of a single national rule and implementation of local management decisions will increase uncertainty because management decisions are made on an ad hoc basis, at each district office, without the benefit of precedent or consistency to guide planning decisions. 3.The use of the Executive Orders referred to in the Rule Notice (e.g., Executive Order 14225) as a basis of fact or truth is neither appropriate nor sufficient justification for rescission of the Roadless Rule. The current administration has demonstrated a bias toward private exploitation of our natural resources on public lands while ignoring the impact of this activity on wildlife habitat and water resources. 4.The notice claims that the rescission is needed to allow greater flexibility in addressing the effects of drought, insect infestations and wildfire that did not exist when the Roadless Rule was adopted in 2001. This current administration has ignored the adverse impacts of climate change on water supply and Forest health. The construction of roads in the Forest will not mitigate the impacts of climate change. This failure to address climate change on the part of the current administration cannot be used to justify increased exploitation of our natural resources. 5.The 2001 Roadless Rule for the Tongass National Forest should remain in place, unless all of the timber harvested from this Forest will be solely for domestic use and not exported.

Re: Opposition to Rescinding the Roadless Rule in the Pecos Wilderness Area, NM I am writing to oppose the proposed rescission of the Roadless Rule as it applies to the Pecos area of the Santa Fe National Forest. As a New Mexico resident, I ask that this protection remain in place. 1. This land is a shared public resource. Taxpaying residents currently use the Pecos for hiking, fishing, and outdoor recreation. We should not sacrifice its beauty and accessibility for the financial benefit of a few private interests. 2. It safeguards water and traditional livelihoods. The roadless backcountry currently helps provide clean air and clean drinking water, and it supports the acequias and traditional irrigation systems that New Mexico communities have relied on for generations. Opening this area to road construction and development risks polluting these water sources. 3. The value at stake is hard to price, but not hard to lose. Clean water, clean air, and intact traditional irrigation are difficult to quantify in dollars and cents, but replacing them once degraded would be enormously costly, if it is even possible. 4. Roads increase wildfire risk. Wildfires are roughly four times more likely to start near roads. Rescinding the Roadless Rule would raise the risk of a fire that could permanently damage this landscape. 5. Destruction is fast; recovery is not. It takes very little time to damage a wilderness area, but decades to restore one, if restoration is possible at all. The Pecos has remained intact because of protections like this one. We should not undo that now. For these reasons, I urge the Forest Service to withdraw this proposal and keep the Roadless Rule protections for the Pecos area in place. Thank you for considering my comment.

I live in Santa Fe, in northern New Mexico. I oppose rescinding the 2001 Roadless Area Conservation Rule. The roadless areas within the Santa Fe National Forest contain the watersheds where we get nearly half of our drinking water. I don't want these areas, or my drinking water, polluted by mine runoff or industrial waste. Creating new roads would be harmful to local wildlife species that are economically important to northern New Mexico. Whether roads are paved or not, there's plenty of evidence that wild animals avoid them. Creating new roads effectively carves up wildlife habitat into smaller "islands" that support fewer animals. And it hurts species like mule deer and elk that depend on migratory routes for their survival. Those species help local businesses by drawing hunters, fishermen, hikers and campers to our area. I've read claims that the roads are needed to help in fighting wildfires. The federal government's own wildfire data undercuts that claim: it shows that most wildfires start near roads and are human-caused. Finally, it's not clear why this administration, with its stated concern for government spending, would want to incur more costs by making the forest service create and maintain even more roads - especially when they're way behind on maintaining the forest roads that already exist. Instead of rescinding the roadless rule, I'd recommend leaving it as is. Doing so would help safeguard our sources of drinking water, would avoid increasing wildfire risk (a matter of deep concern, given the devastating wildfires that we've seen in the Sangre de Cristo mountains), and would avoid increasing the financial burden on the U.S. Forest Service. Please leave the 2001 Roadless Area Conservation Rule intact.

RIN 0596-AD66 / Docket FS-2025-0001 — Public comment opposing rescission of the 2001 Roadless Area Conservation Rule I am a mechanical engineer with 14 years of experience in power generation and water resources, and I live in Phoenix, Arizona. I am submitting this comment as a private citizen and public land owner. Roadless country is not something I visit occasionally. My calendar is built around it, and it is a primary reason I choose to live, work, and spend my money in Arizona, New Mexico, Colorado, Utah, California, Idaho, and Washington. Winter is spent skiing in the San Francisco Peaks on the Coconino National Forest (34.4220, -111.7338) and in the San Juan Mountains. Spring is runoff and rivers — the Colorado, the Little Colorado, the Salmon, the Dolores. Summer is high country hiking, biking, and fishing on the Fishlake (38.8799, -112.0654) and Manti-La Sal (39.0685, -111.3542) National Forests in Utah, the Inyo on the east side of the Sierra (37.6940, -118.3101), and the Cascades on the Okanogan-Wenatchee (47.3857, -121.0103). Fall is elk, in the Mazatzal country of the Tonto National Forest (34.0642, -111.7800), the White Mountains of the Apache-Sitgreaves, and the headwaters of the Santa Fe National Forest in northern New Mexico (36.1209, -106.2424). Every one of those trips runs on gas, food, lodging, licenses, tags, and gear bought in rural towns near those forests. The unroaded character of those places is the product I am paying for. Professionally, I manage capital projects, reliability, and deferred maintenance backlogs for a living, and I have done watersystem and water balance analysis in the arid Southwest. From that perspective the economics in this proposal do not hold up: • The proposal projects $5.2 to $11.4 million per year in Treasury and Forest Service revenue against an acknowledged $6.9 billion deferred maintenance backlog for roads and bridges. That is a return three orders of magnitude smaller than the liability the agency already cannot fund. In any asset management program I have worked in, adding new assets while a backlog of that size goes unaddressed is how systems fail. • The agency's own analysis estimates roughly $6.1 million per year in lost recreation economic benefit — which cancels out most or all of the projected timber revenue to the Treasury. The proposal is close to a net wash at best. • The proposal concedes that management opportunities would be "modest and localized," yet it exposes about 18.2 million acres (45.5 percent of the affected environment) to permanent road construction. The action is vastly broader than the need it claims to address. • If wildfire and community protection is the driving need, the analysis shows only 9.8 million acres — 24 percent — of inventoried roadless area overlaps the wildland-urban interface. That means 76 percent of the acreage being opened has no WUI justification at all. I would support an alternative narrowly scoped to fuels treatment in the WUI. Full rescission is not that alternative. • The DEIS does not adequately quantify what is actually being traded away: loss of elk and mule deer security habitat and migration connectivity, and sediment and turbidity impacts to headwater watersheds that supply municipal and industrial water. In the Southwest, forested headwaters are water infrastructure. Road density is one of the strongest predictors of sediment delivery, and that cost lands downstream on water users, not on the timber balance sheet. • Finally, the existing state-specific rules for Idaho and Colorado demonstrate that locally tailored roadless management is already achievable through petition and rulemaking. That undercuts the premise that a national rescission is necessary to escape a one-size-fits-all rule. I support the no action alternative. As a hunter, angler, skier, rafter, explorer and public land owner, I urge the U.S. Forest Service (USFS) to reject the proposed rescission of the 2001 Roadless Rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Thirty years of camping and hiking in the Pecos Wilderness have given my family something we do not want to lose. We go there because it is remote and wild. In the high country and along the Pecos River we look for elk, deer, and bighorn sheep, for red-tailed hawks, songbirds, and Steller's, Piñon, and Scrub jays. My kids grew up in that place and they want to return to it with their own families. The Pecos inventoried roadless area in the Carson National Forest and El Invierno in the Santa Fe National Forest are part of what makes that possible. The proposal to rescind the 2001 Roadless Area Conservation Rule threatens both, and I oppose it. The agency has justified this rescission in part on wildfire and fuels management grounds, but its own record contradicts that justification directly. 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." We have already seen fire damage in the Pecos Wilderness and we do not want to see more damage from man-made causes. Roads bring more ignitions, and the agency's own draft environmental impact statement confirms it. I ask that the agency reconcile this proposal with DEIS Table 21, which reports far higher fire density on roaded land than inside affected roadless areas, and explain in the record why its stated justification departs from its own prior findings. The economic case for rescission is just as weak. The agency's record shows that the timber volume affected by this rule is less than 0.5 percent of total United States production and that oil and gas production from all National Forest System lands is about 0.4 percent of national production. Against that, the agency's own cost-benefit analysis projects timber revenue of $5.2 to $11.4 million a year to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. The agency cannot even establish a net benefit in its own analysis, yet it proposes to expand a road system already carrying a $6.9 billion maintenance backlog. I ask that the agency explain how an action whose own numbers fail to confirm a net gain justifies that expansion. My family looks for elk and deer throughout the forest and in the riparian corridors near the Pecos River. The agency's own citations show that elk avoid areas near roads and select unroaded habitat with cover and forage, and that elk survival rates rose during a road closure and fell again when the gates were removed. The DEIS cites research finding that roads built for extraction may have altered mule deer migration routes and increased their movement speed. Commenters specifically asked the agency to protect big game habitat, fisheries, and wildlife connectivity, and Alternative 3 was built to address those concerns. The agency then chose the alternative that protects none of it. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres, and 739 municipal water intakes in the Southwestern region sit in watersheds containing affected roadless areas. Clean water is a finite resource, and the agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I want the agency to state clearly in the record why it chose an alternative that abandons the wildlife and watershed protections commenters specifically requested. The proposal also argues that state-by-state approaches can substitute for a national rule. But the agency's own record quotes its prior position that the Roadless Rule reflected an "inflexible 'one-size-fits-all' nationwide rulemaking approach," and a court has already evaluated what happens when the agency acts on that view. The Tenth Circuit, exercising jurisdiction under 28 U.S.C. Section 1291, reversed and remanded the district court's permanent injunction and held that the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA. The agency must explain how this proposal avoids the deficiencies that doomed the previous state-by-state replacement, and address the Tenth Circuit's holding that the rule did not create de facto wilderness. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the 2001 rule. It has held none to undo it. My family has been part of this place for over 30 years. The old-growth spruce, fir, and aspen in the Pecos Wilderness exist because some lands were kept from roads and development. That is not an accident. It is a policy choice, and this administration should not reverse it without answering the questions its own record raises. Sincerely, Susan Schauer White Rock, NM

I am a citizen of New Mexico and I am writing to strongly oppose rescission of the Roadless Rule. The Roadless Rule is twenty-five years old and was established after 600 public meetings and 1.6 million comments by the public. The establishment of the Roadless Rule followed one of the broadest public engagement efforts ever by the US Forest Service, and that showed once and for all that there is outstanding positive support for protecting roadless forests. In New Mexico alone, there are 1.6 million acres of Inventoried Roadless Areas. It is important to me personally to keep New Mexico forest areas free of roads, logging and extractive industries. First of all, my family is fed by the venison, duck, elk and fish that my brother, a licensed hunter and fisherman, hunts and catches on roadless areas including in the Pecos Wilderness, the Lincoln National Forest and the Carson National Forest. Secondly, although I live in Albuquerque which is a metropolitan area of about a million people, for my mental health, I can quickly escape the city and hike or snowshoe in the nearby Cibola National Forest. I also hike and snowshoe in the Santa Fe National Forest; in fact, some of my most important memories of my mother, who died in 2025, are of us snowshoeing together in National Forest lands. I would be devastated if I were to return to those places and find them criss-crossed with roads. Thirdly, as a taxpayer, I am completely opposed to using my tax dollars to build new roads which then are more likely to increase forest fires—which also need to be fought using my tax dollars. A January 2026 scholarly article in journal Fire Ecology [full citation below*] concluded that: “The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha).” In plain English that means that fires are most likely to start within 50 meters of roads, not in roadless areas. So, please, don’t try to claim that the repeal of the Roadless Rule is to prevent or reduce wildfires—we, the public, know better! In summary, keep the Roadless Rule as is--it has served the voting public well for twenty-five years and there are no valid reasons to change it. * Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2

Dear Secretary Rollins and U.S. Forest Service Officials, As a backpacker and hiker who frequently explores the Santa Fe National Forest, the majestic Pecos Wilderness, and other western National Forests I am writing to strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule.For a quarter-century, the Roadless Rule has protected roughly 50 million acres of undeveloped public lands from commercial logging and destructive roadbuilding. In New Mexico, these protections are vital. Backcountry areas adjacent to the Pecos Wilderness provide critical buffer zones that keep entire ecosystems intact, protect the headwaters of the Pecos River, and safeguard essential wildlife corridors for elk, bighorn sheep, and black bears.The argument that removing these protections helps mitigate wildfire risk runs contrary to the reality on the ground. Our National Forest system already contains over 370,000 miles of existing roads. Adding more roads into remote, rugged terrain only further fragments habitats, degrades watersheds, and increases human-caused wildfire risks.We must maintain the existing balance that allows for essential forest health treatments near communities without sacrificing our last remaining wild, unroaded landscapes. I urge the USDA and the Forest Service to listen to the public, protect New Mexico's wild places, and keep the Roadless Rule intact. Sincerely, David Minsk Santa Fe, New Mexico