Read the comments.

I object to rescission of the roadless rule and support Alternative 1, no action, due to the impacts of invasive plant species. I live adjacent to public lands in Eastern Idaho and Western Wyoming where invasive plant species have become a serious concern. In my own experience, trails in Wilderness and Wilderness Study Areas like the Gros Ventre Wilderness, Southern Wyoming Range, and Palisades Wilderness Study Area have very few occurrences of species like Musk Thistle, Canada Thistle, and Spotted Knapweed while roads and trails open to motorized use have populations from occasional individuals to full-blown infestation. One grazing lease adjascent to our farm in Victor, Idaho, on BLM land with a road easement through it, is absolutely infested with Musk Thistle, threatening the economic viability of the lease, spread to the adjacent Targhee National Forest, and increased wildfire risk. It is an economic disaster happening in slow motion. For the specifics of the proposed rescission, my objection rests on the fact that Alternatives 2 and 3 would be in direct conflict with a standing executive order. This order, Executive Order 13751, commits agencies to avoid worsening the problem of invasive plant species and the USFWS’s own Biological Assessment makes clear that roads (and their construction) “create favorable conditions for invasive plants by providing light gaps, dispersal corridors, and reduced competition.” This analysis also states that 60 percent of taxa studied are threatened by invasive or non-native species. The DEIS does not include this finding, nor the 60 percent figure. The DEIS openly admits on page 116 that Alternatives 2 and 3 “could potentially increase the extent or the number of incisive plant species in the affected environment area." This contradiction must be resolved. All of this is to say the obvious: roads bring with them invasive plant species that, once established, are very difficult to deal with and cause significant economic damage. In my area, rescission of the roadless rule would threaten the economy of our valley which relies heavily on recreational tourism. It would also potentially increase wildfire risk. Our functional forest ecosystems are a resource we can't afford to lose.

I am writing to strongly support the 2001 Roadless Area Conservation Rule and urge the agency to keep it in place. I am a resident of Victor, ID and I live and recreate near Targhee National Forest.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The wild and rough roads of my Utah, and the Teton and Yellowstone country, places I go to get away from people, to be with my family, and to experience nature as it has been left. The West Slope Tetons, 47,448 acres in the Targhee National Forest in Wyoming, is land I want to remain untouched, wild, and beautiful. These are the places worth protecting, and the proposal to rescind the 2001 Roadless Area Conservation Rule threatens all of them. I oppose this rescission. Our public land belongs to every American, present and future. That is not a sentiment; it is what the law has always recognized. These areas matter for watersheds, for wild ecosystems, and for what our children will be able to find and explore. Wyoming alone holds 116 inventoried roadless areas totaling 3,243,958 acres, and 325 municipal water intakes in the Rocky Mountain region sit in watersheds containing affected roadless areas. The agency's own figures make the stakes concrete. The roadless areas spread across the Wasatch-Cache, Uinta, Dixie, Ashley, Fishlake, and Manti-La Sal National Forests in Utah, areas like the 355,684-acre Goose Egg Peak in the Ashley, the 121,967-acre Lakes area in the Wasatch-Cache, and the 110,690-acre Boulder Mtn. complex in the Dixie, represent a scale of unbroken landscape that once opened by road does not return to what it was. I have watched fire seasons tear through and strip the green from an area. It is devastating, but I have also seen groundcover and new trees spring from scorched land over time, because fire is part of nature and forest can regrow. What concerns me is that changes to the roadless rule could exacerbate fires and lead to incredible damage to recently burned or regrowth areas. 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." The proposal justifies rescission partly on wildfire management grounds, yet this language is already in the agency's record. I ask that the agency explain why this proposal departs from its own prior findings, and that it reconcile the rescission with the ignition data in DEIS Table 21. The economic case offered for rescission does not hold together. 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, the agency's own Cost Benefit Analysis projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. The road system the agency already maintains carries a $6.9 billion maintenance backlog. The agency must explain how expanding that system, for a resource share measured in fractions of a percent of national production, serves the public interest when its own analysis cannot establish a net benefit. The agency argues that state-specific approaches can replace one national rule. The record itself contains this: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency has been down this road before. The Ninth Circuit found deficiencies in the prior attempt to substitute local decision-making for the national rule, on the specific grounds that local processes can incrementally erode nationally significant roadless values. How does this proposal avoid those same deficiencies? The agency has not said. Finally, the agency argues the 2001 rule exceeded its statutory authority. That argument has already been tested. The Tenth Circuit held: "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 court found the 2001 rule within the authority Congress granted and held that it did not create de facto wilderness. The agency must state on the record the legal basis for any position contrary to that holding. These places deserve to stay wild. They should remain a treasure that can only be found with the patience, grit, and exploration it takes to get there. That is the gift we owe to our children, and it is what this rule, built on more than 600 public meetings and 1.6 million comments, was designed to preserve. The agency should not undo it without answering the questions its own record raises. Sincerely, Jon Mortensen Ogden, Utah 84403

To the USDA and Forest Service, I am writing as a concerned citizen, a resident of a community east and downstream of the Washington & Jefferson National Forest, a former resident of Mount Hood National Forest, and as a parent who loves hiking, camping, and creating memories in the wild areas of National Forests across the U.S. with my children. I urge you to maintain the Roadless Rule. Rescinding it is not only environmentally damaging but also fiscally irresponsible. My opposition is rooted in personal experience with the devastating economic and human costs of road-facilitated disasters, infrastructure neglect, and the loss of the wild spaces that define our quality of life. 1. The Economic Impact of Human-Caused Fires I have personally witnessed the scars of human-caused wildfires in National Forests. In 2015, I drove through Yellowstone and saw the lingering damage from the 1988 North Fork Fire that started near a road inside the adjacent Targhee National Forest and destroyed over 400,000 acres. Even 25 years later, the area was a monoculture of lodgepole pines rather than a resilient ecosystem. The logger that started the fire by tossing a lit cigarette, only had access because logging roads allowed him into vulnerable, drought-stricken stands. Without those roads, that ignition would have been impossible. Roads invite human presence into deep wilderness, exponentially increasing ignition risk. The problem is only getting worse, and the economic toll is staggering: - The 2020 Creek Fire (Sequoia NF, CA): Sparked by an overheating vehicle catalytic converter on a roadside, this fire burned 380,000 acres and cost $193 million to suppress, destroying 63 homes. - The 2026 Oregon Wildfire Season: Record-breaking suppression costs reached an all-time high of $1.4 billion statewide. Localized blazes near Mount Hood, such as the 94,000-acre Grasshopper Fire, destroyed 8 homes and 25 minor structures, heavily disrupting the regional recreation economy. 2. Personal Impact on Mount Hood Communities I owned a cabin on Mount Hood and personally felt the fear communities experience when forest fires threaten their homes. I saw our local businesses suffer as tourists stayed away. But it’s not just fires that drive tourists away; it’s also the polluted rivers caused by road runoff and the fragmented, clear-cut landscapes that replace our wild forests. These factors directly harm the recreational tourism that drives the local economy and supports rural livelihoods. The Mount Hood NF and the broader Columbia River Gorge region alone normally generates $500–$600 million annually. 3. Water Security and Fiscal Responsibility I have seen rivers that once ran clear turn brown from road runoff. Failed roads & poor drainage are leading sources of sediment and pollution in National Forest waterways. This sedimentation chokes fish spawning beds, threatens food security for communities relying on fish, and destroys the recreational fishing tourism that drives local economies. Furthermore, roadless areas protect 354 municipal watersheds across the US, supplying drinking water to millions and saving communities millions in filtration costs. The community where I lived in the Mount Hood National Forest relies on a community well for drinking water. Rescinding the rule weakens these protections, directly threatening the quality and affordability of my water. As a resident downstream of the Washington & Jefferson National Forest, I also understand how vital intact forest landscapes are for maintaining water quality & flood control for downstream communities. 4. The Forest Service Road Maintenance Backlog There is already an estimated $19.3 billion backlog for the existing 220,000+ National Forest roads. The Forest Service is chronically underfunded & forced to prioritize fire suppression over infrastructure maintenance. Maintaining existing roads costs approximately $3.8 billion annually. I believe it is fiscally irresponsible to build new roads when existing ones are deteriorating. These crumbling roads pose safety risks to my family and the public. In my Mount Hood community, the fire department is all-volunteer. I watched our community burn & saw volunteer firefighters work 24-hour shifts to protect our homes. Poorly maintained roads impede emergency access & increase erosion, complicating recovery efforts. In conclusion, I do not believe more roads should be built when the existing system is failing. I want to ensure my children inherit a legacy of clean water & wild, unfragmented forests, not a multi-billion dollar maintenance backlog. The Roadless Rule is the only thing standing between our children & a future where “wild” is just a memory. Please do not rescind the Roadless Rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001. 50 years living in NCDE & Yellowstone Region has given me solace based in truth so cannot tolerate rescission in exchange for marketization of public lands. RR means protections not their removal.RR lands mean connectivity for species survival. Rescission displaces threatened species. ESA listed grizzly bear requires best science. Rescission shuns it and will prove fatal for grizzly populations. Cited lands mirror grizzly DPS compliance. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, specifically inventoried RR areas: Lost Water Canyon (9,251 acres), Custer NF, MTBurnt Mountain (10,698 acres), Custer NF, MT Black Butte (871 acres), Custer NF, MT Red Lodge Creek Hellroaring (17,210 acres), Custer NF, MTOkanogan-Wenatchee NF (1,006,000 acres), Okanogan NF, WAGifford Pinchot National Forest (213,000 acres), Gifford Pinchot National Forest, WAMt. Baker-Snoqualmie NF, WALiberty Bell (108,495 acres), Okanogan NF, WACuster Gallatin NF (848,000 acres), Custer Gallatin NF, MTBob Marshall Wilderness Complex (1,483,000 acres),Bob Marshall Wilderness Complex, MT Paine Gulch (7,875 acres), Lewis & Clark NF, MTMt. High (33,484 acres), Lewis & Clark NF, MTMcgregor - Thompson (27,211 acres), Lolo NF, MTDeep Creek (7,669 acres), Lolo NF, MT Trout Creek (30,851 acres), Kootenai NF, MTCataract (9,442 acres), Lolo NF, MTBlue Slide (17,505 acres), Wenatchee NF, WA Mt. Baker-Snoqualmie NF (415,000 acres), Mt. Baker-Snoqualmie NF, WA , Okanogan NF,Pasayten Rim (17,074 acres), Okanogan NF, WASawtooth (15,693 acres), Lewis & Clark NF, MTwin Sisters (13,051 acres), Colville NF, WA Bridger-Teton National Forest (1,417,000 acres), Bridger-Teton National Forest, WyWest Pioneer (248,631 acres), Beaverhead-Deerlodge NF, MTBear - Marshall - Scapegoat - Swan (344,022 acres), Lewis & Clark NF, MT Bob Marshall-Scapegoat-Swan (334,275 acres), Flathead NF, MT East Pioneer (145,082 acres), Beaverhead-Deerlodge NF, MTWest Big Hole (133,563 acres), Beaverhead-Deerlodge NF, MTMadison (127,859 acres), Gallatin NF, MTSelway-Bitterroot (114,953 acres), Bitterroot NF,MTHoodoo (105,162 acres), Lolo NF, MTAllan Mountain (104,184 acres), Bitterroot NF, MTSnowcrest Mountain (97,649 acres), Beaverhead-Deerlodge NF, MT Freezeout Mountain (97,305 acres), Beaverhead-Deerlodge NF, MT Middle Mtn. / Tobacco Roots (96,487 Beaverhead-Deerlodge NF, MTTuchuck (17,730 acres), Flathead NF, MTThompson Seton (52,235 acres), Flathead NF, MTMt. Henry (13,603 acres), Kootenai NF, MTOlympic National Forest (86,000 acres), Olympic National Forest,WASapphires (66,619 acres), Beaverhead-Deerlodge NF,MTBear Creek (8,123 acres), Beaverhead-Deerlodge NF, MT MTLittle Bighorn (133,949 acres), Bighorn NF, WyoSleeping Child (x1074) (21,433 acres), Bitterroot NF, MT, Bitterroot NF, MTDry Canyon Breaks (4,821 acres), Colville NF, WANorth Absaroka (21,063 acres), Custer NF, MTCrazy Mountain (82,093 acres), Gallatin NF, MTBridger (45,059 acres), Gallatin NF, MTHyalite - Porcupine - Buffalo Horn Wilderness Study Area (143,991 acres), Gallatin NF, MTGallatin Fringe (51,571 acres), Gallatin NF, MT Cabin Creek Wildlife Management Area Ocd (35,048 acres), Gallatin NF, MTWAHellgate Gulch (16,821 acres), Helena NF, MTBig Snowy Mountains Wsa (88,003 acres), Lewis & Clark NF, MTCastle Mountains (29,409 acres), Lewis & Clark NF, MT Crazy Mountains (24,942 acres), Lewis & Clark NF, MT Box Canyon (12,584 acres), Lewis & Clark NF, MT- Big Snowies (9,258 acres), Lewis & Clark NF, MT North Fork Smith (8,444 acres), Lewis & Clark NF, MT Tenderfoot - Deep Creek (85,614 acres), Lewis & Clark NF, MT Eagle Park (5,912 acres), Lewis & Clark NF, MT- Calf Creek (10,108 acres), Lewis & Clark NF, MT- Pilgrim Creek (44,608 acres), Lewis & Clark NF, MT Highwood Baldy (15,305 acres), Lewis & Clark NF, MT Highwoods (24,378 acres), Lewis & Clark NF, MT- TW Mountain (8,388 acres), Lewis & Clark NF, MT Granite Mountain (10,338 acres), Lewis & Clark NF, MT Lewis & Clark NF, MT Middle Fork Judith Wsa (81,131 acres), Lewis & Clark NF, MT Bluff Mountain (38,060 acres), Custer NF, MtLine Creek Plateau (24,825 acres), Custer NF, MT, Custer NF, Mt Shoshone NF, WyoWilderness Study Area (51,961 acres), Targhee NF, Wyo- West Slope Tetons (47,448 acres), Targhee NF, Wy- Silver King (64,289 acres), Beaverhead-Deerlodge NF, Montana, - Selkirks (95,967 acres), Idaho Panhandle NF, Idaho-Grizzly Peak (7,441 acres), Kootenai NF, Montana I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects threatened species and of climate change.I ask that the agency respond to each of them.I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Dan Sullivan Chanhassen, MN

My name is Kathryn Nyrop and I live in Wilson, WY, adjacent to the Bridger Teton National Forest. I walk in the forest daily and also explore and appreciate Targhee National Forest and all national forests in our beautiful country. Part of the reason these forests are so beautiful and important is that they have been saved from road development for over 25 years. I strongly support the “No Action” Alternative 1 that would maintain protections for our Roadless Forests, and I strongly oppose Alternatives 2 and 3, which would strip their protections. Roadless Areas are critical to fresh drinking water, animal habitat, and opportunities for recreational access. Given the recent cutbacks on funding for our national forests, I do not believe that more roads are needed when we can't maintain what we have. Furthermore, more access via roads degrades the value of the natural outdoors, which the public clearly does not want to see harmed. Out of a very lengthy list of reasons to keep the Roadless Rule in place, perhaps the most relevant and important argument is that it is what the American people, whose public lands it protects, are in overwhelming favor of! Keep our public lands public and protected.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The land I am writing about is land I own, in common with millions of other Americans, and I live on the west slope of the Tetons in Idaho. I know the sorry history of logging here and the damage it has caused to wildlife, and for what? The vast majority of trees cut for lumber are already grown on private land. Logging public land, where the value of the timber harvest is far less than the cost to the government of enabling it, is a great waste of taxpayer dollars. Talk about waste, fraud and abuse. This proposal to rescind the 2001 Roadless Area Conservation Rule deserves none of the agency's stated justifications, and I oppose it fully. The Forest Serive'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." This confirms what I have long argued. There is no meaningful national supply case for opening these lands. The proposal claims economic and employment benefits, but the agency's own cost-benefit analysis projects only $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 range spanning -$92 million to +$199 million. The road system this proposal would expand already carries a $6.9 billion maintenance backlog. How does an action whose own analysis cannot establish a net benefit justify that expansion? The agency must address this question directly in its final record. The West Slope Tetons roadless area adjacent to where I live covers 47,448 acres in the Targhee National Forest. Wyoming holds 116 inventoried roadless areas totaling 3,243,958 acres. I have watched what roads do to this landscape, and the agency's own analysis tells the same story about fire. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission partly on wildfire and fuels management grounds, yet this finding sits in the agency's own draft environmental impact statement. The agency must reconcile its stated rationale for rescission with its own ignition data, specifically DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain the departure from its prior findings. The Forest Service claims the rule imposes administrative hardship, but the rule as written already provides relief. 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 for public health and safety, existing mineral leases, and community wildfire protection are already there. The agency has not identified which specific burdens fall outside those existing exceptions. It should do so, with numbers attached, before proceeding further. Finally, the regulatory flexibility analysis certifies no significant impact on small businesses while the record shows outfitters, guides, and tour operators operating in these areas will be affected. The proposed rule itself acknowledges this: "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 certification was reached by spreading an estimated loss across every small firm in the sector nationally rather than examining the firms actually holding permits in the affected roadless areas. The agency should withdraw that certification and conduct a proper assessment of the small entities actually operating here, not the national average firm. I file these comments under Docket FS-2025-0001 and ask that the agency address each point in its final decision. Sincerely, Frederick Johnson Tetonia, Idaho