Read the comments.

It is extremely important that we keep the 2001 Roadless Rule the way it is. Here are some quick facts: - From 1992 to 2024, wildfires were four more times as likely to start in areas with roads than in roadless areas. - Our National Forests are a vital source of water for millions of Americans. Roads are a major source of water pollution, threatening our clean drinking water. - Fragmented forest areas are worse habitats for the species that are vital for the health of forests and other ecosystems. - The Roadless Rule already has built in flexibility for exceptions. The forest service can build roads as needed to address fires, floods, and other catastrophes. The Roadless Rule is so important for protecting our public land and wildlife from pollution, fires, and other human caused threats to our ecosystems, and it already has built in safe-guards for preventing forest fires and other disasters. Our forests do not need to be 'productive.' We do not need to log every tree in the United States. Forests are valuable resources in their own right, especially when they are minimally impacted by humans. We need to take a step back and stop the ruthless commoditization of every square foot of land available in our nation. Rescinding the Roadless Rule is not a step back, but a dangerous step towards this commoditization. I grew up in North Idaho recreating on roadless lands. I grew up backpacking in Idaho Panhandle National Forests by Priest Lake in some of the most pristine forests I have ever seen. I took a group of friends from Wisconsin backpacking through Hells Canyon in Nez Perce National Forest, and then visited the canyon again the same year with my best friend. I've been exploring Sawtooth National Forest since I was 8 with my family. I've climbed huge mountains in Salmon-Challis National Forest. Idaho is one of the most beautiful and untouched states in our nation because so much of its national forest land has been designated as roadless, and one of the greatest pleasures of my life has been experiencing these places for myself. Rescinding the roadless rule creates so many risks that threaten to take these experiences away permanently, from myself and millions of other Americans. Logging, pollution, and increased risks of fires associated with human-constructed roads are extremely preventable issues: just don’t build the roads. We don’t need them. Please, listen to the pleas of the thousands and thousands of Americans asking you to keep the Roadless Rule intact. Henry DePew

Opposition to Proposed Rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) Dear U.S. Forest Service: I am writing to express my strong opposition to the proposal(s) to fully or partially rescind the 2001 Roadless Area Conservation Rule, and I urge the agency to select Alternative 1 (No Action) in the Draft Environmental Impact Statement (DEIS). I am a resident, backcountry recreationist, small outdoor industry business owner, hunter, and conservationist, living in Hailey, Idaho. I regularly recreate in or depend upon the clean water and healthy ecosystems of the Sawtooth National Forest, and the Salmon & Big Wood watersheds. The Roadless Rule is the most popular rule ever implemented in USDA’s history. When it was first proposed in 2001, the Roadless Rule received 1.6 million public comments—more than any rule in U.S. history at that time. Over 95% of these comments supported keeping roadless protections. The Roadless Rule is vital for protecting our remaining undeveloped national forest lands. These inventoried roadless areas provide critical ecological benefits, including high-quality drinking water sources, pristine wildlife habitats, and essential carbon storage that aids in climate resilience. Furthermore, these unfragmented landscapes support robust outdoor recreation economies and preserve valuable natural heritage for future generations. The Forest Service itself stated in the text of the Roadless Rule that conserving roadless areas was critical because road construction and logging were the activities “most likely to harm” the characteristics and values the agency is tasked with protecting. That remains true today. Rescinding these protections would open sensitive wildlands to road construction, commercial logging, and resource extraction, leading to habitat fragmentation, increased fire risks, and permanent damage to vulnerable ecosystems. Managing existing infrastructure should take priority over opening intact roadless areas to costly new development. The text of the Roadless Rule itself acknowledges that the Forest Service could not maintain its existing road system to safety and environmental standards. That reality has only worsened as budgets continue to shrink. I request that the Forest Service withdraw the proposal to rescind the Roadless Rule and maintain the protections of Alternative 1(No Action) across all 44+ million acres of Inventoried Roadless Areas. Please, we must protect America’s remaining roadless areas for current and future generations. Thank you for considering my comments. Sincerely, Heather Dawnstar Guess

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My family hikes and camps in these areas to slow down and get back to the basics that nourish us - connection with each other and nature. We feel fortunate to have places like the High Uintas Wilderness and the roadless area of Pettit in the Sawtooth National Forest, and we must protect these wild spaces from development for future generations, including our son as he grows. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres, and the families who depend on those lands have every reason to question what the agency proposes to do here. The Pettit roadless area in the Sawtooth National Forest has given our family many wonderful memories through the years. Rescinding the 2001 Roadless Area Conservation Rule puts places like Pettit and the High Uintas at risk of the very road construction and surface disturbance the rule was designed to prevent. The agency has not shown it understands what it is trading away. The proposal justifies rescission in part on wildfire and fuels management grounds, but the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Expanding the road system into the landscapes where we hike and camp does not reduce fire risk; the agency's own prior findings say it increases it. I ask that the agency explain why the proposal departs from those findings and reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic justification is no stronger. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that negligible extraction benefit, the agency's own Cost Benefit Analysis projects recreation losses of at least $6.1 million a year and a net present value that spans from deeply negative to modestly positive, while the existing road system already carries a $6.9 billion maintenance backlog. Across the Intermountain region, which includes Utah and the High Uintas watershed, 1,466 municipal water intakes sit in watersheds containing affected roadless areas, a cost the analysis does not appear to internalize at all. How does the agency justify expanding a system it cannot afford to maintain, in pursuit of revenues its own numbers show are negligible? The regulatory flexibility analysis does not hold either. "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 Sawtooth National Forest supports guided outfitting and recreation that depends on the character of roadless land. Spreading an estimated $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the permit holders actually operating in the affected areas, is not a serious analysis of impact. I ask that the agency withdraw the certification and assess the consequences for the small businesses actually holding permits in the potentially affected roadless areas. Finally, "The proposal solicits 'any reliance in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." My family has made choices about where to go, where to invest time and memory, based on the protections the 2001 rule provides. This comment is exactly the kind of reliance interest the agency invited and is now obligated to weigh. The agency must identify and account for the reliance interests described in the comments it receives, including this one, before it takes any further step toward rescission.

Technical Comments on the Proposed Rescission of the 2001 Roadless Area Conservation Rule Submitted by: Avalanche Risk Solutions, LLC Docket: FS-2025-0001 RIN: 0596-AD66 Proposed Rule: Special Areas; Roadless Area Conservation Federal Register Citation: 91 FR 53827 Significant evidence exists that an increase in roads within forest lands is directly correlated to an increase in wildfire activity within those areas (Aplet et al., 2026) A known but often overlooked result of wildfire is a correlated increase in snow avalanche activity (Campbell et al., 2019). Mature forest acts as anchorage for snowpacks on steep hillsides in the western United States. Forests also have a slowing effect on avalanches that start above them and typically reduce the risk to people and structures at lower elevation. When this mature growth is eliminated through wildfire or cutting this anchoring effect is eliminated and new avalanche paths are created. This newly created avalanche terrain increases hazards to recreational users, infrastructure, and in some western communities urban areas. Urban infrastructure commonly exists below designated roadless areas. Prominent examples include the Wasatch Front of Utah; and Warm Springs Road in Ketchum, Idaho. This increase in hazard may result in the loss of life or property. An example of this increased hazard is Blaine County, Idaho. Wildfire activity in this area has fundamentally altered the avalanche hazard affecting the wildland/urban interface and thus greatly increased avalanche threats to roads, people and property. (Miller et al., 2023). The United States Geological Survey (USGS) recognizes this threat and has gone as far as publishing it on USGS.gov (pubs.usgs.gov/publication/70249585). There is a known and correlated increase in avalanche activity as a result of wildfire. It is recognized that the number of wildland fire ignitions increase as humans gain road access, far outweighing the benefit of increased firefighting response time. Wildfire impacts will increase in the western United States as a direct result of rescinding the roadless rule, and thus the avalanche hazards shall also. We recommend that the US Congress uphold the roadless rule on USFS lands and avoid compounding the problems from wildland fire and avalanches. -Ownership and Senior Avalanche Consultants of Avalanche Risk Solutions LLC David Richards Donald Sharaf Kiira Antenucci AVALANCHE RISK SOLUTIONS, LLC (801) 556-5615 INFO@AVALANCHERISKSOLUTIONS.COM References: Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22(8) Campbell, C., Gould, B., & Thumlert, S. (2019). Post Wildfire Analysis of Avalanche Hazard. The Avalanche Journal, 121 (Summer 2019), 22–25. [1] Miller, Z., Sykes, J., Guinn, M., VandenBos, B., Savage, S., and Peitzsch, E.H., 2023, Spatial extent of forested avalanche terrain impacted by wildfire across the Sawtooth National Forest, in Proceedings, International Snow Science Workshop 2023, Bend, OR, October 8-13, 2023, p. 272- 279. AVALANCHE RISK SOLUTIONS, LLC (801) 556-5615 INFO@AVALANCHERISKSOLUTIONS.COM

Subject: Public Comment on Proposed Rule: Special Areas; Roadless Area Conservation (RIN 0596-AD66) To Whom It May Concern, I am writing to submit a formal public comment in strong support of the proposed rule to rescind the 2001 Roadless Area Conservation Rule (RIN 0596-AD66). As a private property inholder located directly west of George Peak in the Raft River Mountains (Sawtooth National Forest, Minidoka Ranger District), my family is directly impacted by the rigid restrictions of the 2001 national mandate. The Raft River range features a highly complex checkerboard of private inholdings and public land. While federal law guarantees inholders "adequate access" to their properties, the 2001 Roadless Rule introduces an extraordinary and punitive layer of federal bureaucracy for basic, low-impact private land use. Specifically, we are planning to construct an off-grid cabin on our private land. While we utilize existing classified system roads (FR-004 and FR-009) for transit, the surrounding Inventoried Roadless Area (IRA) restriction severely complicates the logistics of moving structural materials and essential equipment across the final boundary to our property line. Under the current rule, even temporary, zero-impact access or staging requires exhaustive, multi-year NEPA reviews that strain both landowner finances and local Forest Service resources. Furthermore, the blanket 2001 rule severely restricts the flexibility of local forest managers to quickly approve necessary wildfire mitigation and hazardous fuel reduction efforts along our shared private-public boundaries. I strongly recommend that the USDA finalize this proposed rule to rescind the national 2001 Roadless Rule. Removing this blanket restriction will return land management authority to local Forest Service officials who possess a nuanced understanding of the Raft River division's unique topography and private property boundaries. Local managers are entirely capable of protecting the environment through standard Land and Resource Management Plans without maintaining a restrictive, nationwide barrier that infringes on the practical exercise of private property rights. Thank you for your time and consideration of these pertinent issues. Sincerely, Daniel Patrick Gorney, A Utah Inholding Landowner Manager, Oquirrh Endevours LLC, a Utah Corporation Tremonton, UT 84337

Subject: Public Comment on Proposed Rule: Special Areas; Roadless Area Conservation (RIN 0596-AD66) To Whom It May Concern, I am writing to submit a formal public comment in strong support of the proposed rule to rescind the 2001 Roadless Area Conservation Rule (RIN 0596-AD66). As a private property inholder located directly west of George Peak in the Raft River Mountains (Sawtooth National Forest, Minidoka Ranger District), our family experiences firsthand the severe, on-the-ground consequences of the current "one-size-fits-all" national mandate. The Department’s rational statement correctly notes that the 2001 Roadless Rule has "contributed to the lack of active management of the national forests, which in turn has contributed to challenges in addressing forest health concerns." Our private property is a stark, urgent example of this reality. Currently, the vast majority of the timber on our inholding is dead or dying due to severe insect infestations and disease outbreaks. Because our property is entirely surrounded by an Inventoried Roadless Area (IRA), the strict prohibitions on timber cutting, road reconstruction, and heavy equipment access have made it virtually impossible to actively manage or mitigate this ecological crisis. We cannot safely clear the dead and infested timber, nor can we establish critical fire breaks to protect our upcoming off-grid cabin build and the surrounding public lands. The 2001 rule’s insistence that exceptions be "infrequent" and clear a gauntlet of inconsistent administrative reviews has effectively tied the hands of both landowners and local rangers while the forest health rapidly deteriorates. The dead fuel load on our property and the adjacent federal land poses a catastrophic wildfire risk to the entire George Peak area. As stated in the proposal, conditions in the Western United States have changed substantially since 2001, marked by "increasing drought, extreme temperatures, wildfire frequency and severity, and insect and disease outbreaks." A blanket national prohibition is no longer a viable conservation strategy; it has become an administrative barrier to ecological survival. We strongly agree with the Department’s position that returning primary authority to the local level via the National Forest Management Act (NFMA) framework is the correct path forward. Local decisionmakers at the Minidoka Ranger District thoroughly understand the unique "checkerboard" private-public boundaries and specific environmental crises of the Raft River division. Giving local officials the place-based discretion and flexibility to approve collaborative, active management tools will allow us to address our forest health concerns safely and efficiently. For these reasons, we urge the USDA to finalize the rescission of the 2001 Roadless Rule to restore responsible, localized balance to our public and private forest lands. Sincerely, Rebecca Jane Gorney, Inholder Tremonton, UT 84337

I am submitting this comment in opposition to the Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule. I am a graduate student in the Rangeland, Wildlife, and Fisheries Management program at Texas A&M University, studying plant ecology and restoration. I've also spent a fair amount of time in national forests as a backpacker and climber, including trips through the Sawtooth National Forest and Plumas National Forest, and I've seen firsthand how much of the ecological function and character of these places depends on the fact that they remain unroaded. Several points from the proposed rule and its own supporting documents concern me directly: The wildfire rationale doesn't match the mechanism. The 2001 Rule already permits timber cutting to reduce fuel loads and restore ecosystem structure where doing so maintains roadless character (36 CFR 294.13(b)(1)), and it allows emergency road construction to protect public health and safety during imminent wildfire threats (36 CFR 294.12). What the rule actually restricts is new permanent roads and commercial-scale timber harvest — not the fuel treatments cited as the justification for rescission. If active-management capacity has been limited, that points to budget and staffing constraints (the Department's own analysis cites a $6.9 billion road maintenance backlog), not a regulatory barrier. Roads themselves can elevate fire risk. Independent research, including a 2026 study in Fire Ecology, has found substantially higher ignition density near roads. Opening these areas to new road construction could work against the stated wildfire-reduction goal rather than support it. Watershed and wildlife values. These 58.5 million acres are some of the last large, connected blocks of intact habitat and clean-water source areas remaining in the National Forest System. Fragmenting them with roads has well-documented consequences for water quality and species connectivity that the draft EIS should weigh more heavily against the comparatively modest projected timber and revenue gains (an estimated $5–11 million per year system-wide). Recreation. Inventoried roadless areas carry an outsized share of the backcountry trail and climbing access in the National Forest System. The draft EIS itself estimates roughly $6.1 million per year in lost recreation-economy value from the rescission — a cost borne by hikers, hunters, anglers, and the outfitting businesses that depend on these places staying wild. Tribal consultation. USDA's own Tribal Input Received summary documents that the majority of Tribes consulted oppose this rescission and have raised serious concerns that consultation has not met government-to-government standards. That opposition, from the Department's own record, deserves far more weight than the current timeline allows. I urge USDA to withdraw this proposal and retain the 2001 Roadless Rule (the "No Action" alternative), or at minimum to substantially extend the review process to fully address the concerns raised by Tribal governments and the public. Thank you for considering my comment. Zack Shelley. Auburn, California

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Forty years of hunting in Idaho and Montana has taught me one thing clearly: large roadless areas are essential to quality game habitat. I also fish small streams and lakes, and I have watched those areas degrade when roads are extended into them. I hike and camp in roadless areas outside designated wilderness, including in the Cassia Ranger District of the Sawtooth National Forest, where there are hundreds of miles of motorized trails and less than 20 miles of nonmotorized trails. The claim that the nonmotorized rule should be revoked to provide equal access is false. I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The economic case for this rescission does not hold together. The agency's own record states 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." The proposal is being advanced partly on timber economics and employment grounds, yet the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of only $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, and a net present value spanning negative $92 million to positive $199 million. The road system already carries a $6.9 billion maintenance backlog. I ask that the agency reconcile the proposal with those numbers and explain how an action whose own analysis cannot establish a net benefit justifies further expanding that backlog. The proposal is also justified in part on permitting and administrative burden, but the rule as written already accommodates the activities the agency says it impedes. 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. § 294.12(b)(1),(3)." Exceptions already exist for existing mineral leases and community wildfire protection as well. I ask that the agency identify, by name and type, which specific permitting or administrative burdens are not already addressed by those exceptions, and that it quantify those burdens with actual data in the record. The small streams and lakes I fish depend on intact watersheds. Roads extended into roadless areas increase sedimentation and degrade those waters. Across the Intermountain region, which includes Idaho, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The fishing and drinking water implications of opening those watersheds to road construction receive no serious treatment in the proposal. I expect the agency to address watershed protection on the merits. The hunting I have done across Idaho and Montana for forty years depends on exactly the kind of undisturbed, unroaded country this rule protects. The agency's own document acknowledges the evidence: "The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." Idaho alone holds 9,285,371 acres across 280 inventoried roadless areas. Despite citing this finding, the proposal projects no population-level effect on big game and no effect on hunter opportunity anywhere in the document. I ask that the agency project the effects of rescission on big game populations and hunter access before this action proceeds. The biodiversity evidence cited in the agency's own materials is similarly orphaned. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the record and then goes nowhere. No projection applies it across the 40.1 million acres of potentially affected environment. The range is too wide and the stakes too large to leave unapplied. The agency must apply the cited fragmentation finding to the full extent of the affected environment and include that analysis in the final record. The Cassia Ranger District example I described is not an isolated case. Where motorized access already far outweighs nonmotorized opportunity, the access-equity argument for rescission does not apply. The agency should address that imbalance directly rather than treating rescission as a remedy for it.

I oppose rescission of the 2001 Roadless Area Conservation Rule. My husband and I regularly camp and hike in National Forests around the country. We enjoyed the Sawtooth National Forest this May and have returned to the Black Hills National Forest multiple times. The Black Hills is where I began paying much closer attention to wildflowers and the smaller details of an intact forest ecosystem. I have also backpacked extensively in California forests. I am not opposed to logging or active forest management. We frequently camp in areas where timber has been harvested, and I recognize that National Forests are working forests with multiple uses. But preserving some large areas without roads is also an important public use of these lands. Roadless areas provide an experience that cannot be recreated simply by closing a road after it is built. Walking into a landscape without roads provides quiet, remoteness, intact habitat, and the opportunity to experience nature with relatively little human alteration. For me, that also has a spiritual value. Seeing an intact forest—its trees, wildflowers, wildlife, streams, and terrain—is one of the few ways we can still see, as closely as possible, what God created rather than a landscape redesigned for human purposes. I am particularly concerned that the stated wildfire rationale does not justify eliminating protections nationwide. Research cited during this rulemaking indicates that wildfire ignitions occur at substantially greater density near roads than within inventoried roadless areas. The Forest Service should address that evidence and explain why opening currently roadless areas to additional road construction would reduce wildfire risk rather than potentially increase human-caused ignitions. The agency should also consider the cumulative effect of replacing a nationwide roadless protection with individual project decisions. A particular road may appear minor when considered separately, but repeated decisions over many years could gradually eliminate the very characteristic the Rule was intended to preserve. Once roads penetrate an intact landscape, restoring genuine roadlessness is much more difficult than allowing harvested trees to regrow. I recognize that some areas may require mechanical treatment, wildfire mitigation, or other active management. But that supports a targeted approach, not complete rescission. If existing exceptions are inadequate, the Forest Service should identify the specific management problems and adopt narrowly tailored additional exceptions where necessary. I therefore ask the Forest Service to retain the Roadless Rule and, before making any final decision, to: 1. **Analyze the cumulative loss of roadless character** that could result from replacing nationwide protection with individual forest-level and project-level road decisions. 2. **Address the evidence concerning wildfire ignitions near roads** and explain why additional road construction into currently roadless areas would advance the stated wildfire-reduction objective. 3. **Evaluate roadlessness as a distinct recreational, ecological, and experiential resource**, including quiet, remoteness, intact habitat, opportunities to observe natural systems, and the ability to travel through large undeveloped landscapes. 4. **Explain why targeted measures are insufficient**, including existing exceptions, additional narrowly tailored exceptions, or geographically limited treatment of areas presenting demonstrated wildfire or forest-health risks. 5. **Consider an alternative that preserves the general prohibition on new roads** while allowing necessary management in specifically identified high-risk areas. Our National Forests have room for logging, active management, roads, motorized recreation, and developed recreation. They should also preserve some places where the road ends.

Docket: FS-2025-0001 Re: Proposed Rescission of the 2001 Roadless Area Conservation Rule Submitted via: Regulations.gov To the U.S. Forest Service and USDA: I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Department to withdraw this proposal and retain the existing national roadless protections for the approximately 45 million acres they currently cover. Personal connection. I have spent time in the backcountry of the Sawtooth National Forest in Idaho, and while Sawtooth's roadless areas fall under the separate 2008 Idaho Roadless Rule rather than the 2001 Rule this proposal targets, the two policies protect the same kind of landscape for the same reasons. What happens to the 2001 Rule matters to places like Sawtooth: it sets the national precedent and tone for how roadless backcountry is valued and managed, and it protects the neighboring forests, watersheds, and wildlife corridors across Idaho, Utah, Nevada, and Wyoming that Sawtooth's ecosystems and recreation networks connect to. Weakening the national standard makes every regional variant, including Idaho's, more vulnerable to being revisited down the line. Rescission would increase, not decrease, wildfire risk. USDA's stated justification for this rescission is wildfire risk reduction, but the best available evidence points the opposite direction. Roughly 85–89% of U.S. wildfires are human-caused, and multiple independent studies confirm that ignition density rises sharply with proximity to roads: a nationwide analysis of three decades of Forest Service fire records found ignition density was lowest in wilderness and roadless areas and highest within the first 50–250 meters of roads, with ignitions up to four times more likely near roads. Forest Service researchers studying Southern California national forests similarly found that nearly two-thirds of human-caused fires ignited along roadsides. Roads bring the primary driver of ignitions — people — deeper into the backcountry, and they also dry out and fragment forest edges in ways that make ignitions more likely even from natural causes. Opening roadless areas to new road construction would work against the very wildfire-risk goal the Department cites, not advance it. Watershed and habitat values. Roadless areas protect the source watersheds that supply drinking water to tens of millions of Americans downstream. Roads increase sediment delivery to streams, degrade water quality, and fragment wildlife habitat and migration corridors in ways that cannot be undone once built. These are not abstract concerns — they affect the same rivers, fisheries, and big-game herds that depend on the undeveloped high country surrounding forests like the Sawtooth. Recreation and local economies. Roadless backcountry supports hiking, hunting, fishing, climbing, and paddling that draw visitors and sustain local economies across the West. Rescinding the rule puts thousands of miles of trails and undeveloped recreation terrain at risk of fragmentation by new logging roads. Request. I ask that USDA withdraw the proposed rescission and retain the 2001 Roadless Area Conservation Rule in full. If the Department believes local flexibility is needed, that flexibility should be pursued through the forest-specific rulemaking process used for Idaho and Colorado — with full environmental review and public input — rather than by eliminating baseline national protections for the remaining 45 million acres. Thank you for considering my comment.

I oppose rescinding the 2001 Roadless Area Conservation Rule and urge USDA to withdraw this proposal. I've spent time in the backcountry of Idaho's Sawtooth National Forest. Sawtooth itself falls under the separate 2008 Idaho Roadless Rule, but it sits amid the same interconnected watersheds, wildlife corridors, and recreation networks the 2001 Rule protects across neighboring states. Weakening the national standard sets a precedent that puts every regional variant, including Idaho's, at greater risk down the line. USDA cites wildfire risk reduction as justification, but the evidence points the opposite way. Roughly 85–89% of U.S. wildfires are human-caused, and multiple studies — including a 30-year Forest Service ignition dataset — show fire ignition density is highest near roads (up to 4x higher than in roadless areas) because roads bring people, the dominant ignition source, deeper into the backcountry. Building new roads into roadless areas would increase, not reduce, wildfire risk. Roadless areas also protect drinking-water source watersheds, wildlife habitat, and thousands of miles of trails that support hunting, fishing, and outdoor recreation economies across the West. I ask USDA to retain the 2001 Roadless Rule in full rather than eliminate baseline protections for the remaining 45 million acres it covers.