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To whom it may concern, RE: Docket FS-2025-0001-223869 Please accept my formal comment attached as FS-2025-0001-223869_RLC-20261006-J2E3WP.pdf The following sources are cited in support of this comment and are available from their publishers: Public Lands and Cultural Resource Protection: A Case Study of Unauthorized Damage to Archaeological Sites on the Tonto National Forest, Arizona Hedquist, S. L., Ellison, L. A., and Laurenzi, A., 2014 The ecological implications of visitor transportation in parks and protected areas: Examples from research in US National Parks Monz, C., D'Antonio, A., Lawson, S., Barber, J. and Newman, P., 2016 Thank you, Callie Moore Hayesville, NC

Hello, I’m writing to ask we keep and protect the Roadless Area Conservation Rule. We must protect our roadless forests. I live in Arizona where many of our national forests would be affected by additional roads. Rivers like the lower Salt River in the Tonto National Forest will be affected by this as well. Like many areas, this part of the river sustains many species some endangered. It’s also a place where so many of take our families to to escape the city and enjoy the few watersheds the desert has to offer. If we continue to sprawl into roadless and untouched nature- where do we stop? There has to be limits we have to keep places wild for us to recreate in, camp, hunt, and wildlife need it too. Most of wild fires are caused by humans, and most of those human caused fires have been known to start within a mile of roads. More roads lead to more fires, to deforestation and more. Please listen to the people and experts on this. Thank you.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Clean water is a right. That is the frame I bring to this comment, and I will not negotiate it away. I have visited over 15 national parks across this country, including Arches, Canyonlands, Bryce Canyon, and Olympic. I ride throughout the Tonto National Forest. I go looking for beautiful vistas and gorgeous mountains, and I photograph them. These places matter to me, and the 2001 Roadless Area Conservation Rule is part of what keeps them worth visiting. I oppose its rescission. Start with water, because the agency's own numbers make the case. More than 7,000 municipal water intakes sit in watersheds fed by roadless areas, and by the agency's analysis roughly 24 million Americans drink water that originates there. Fewer than 12 percent of those watersheds have impaired streams today. The agency itself has found that roads and their associated facilities can produce up to 90 percent of the sediment from a timber sale. Opening roadless areas to roads is not a minor adjustment: it is a direct threat to the water supply that tens of millions of people depend on. Clean water is a right. We deserve to have access to clean water, and that is non-negotiable. I ask the agency to explain, specifically and on the record, how rescinding the rule is consistent with protecting the watershed quality its own data describes. The wildfire rationale does not hold up either. The agency claims the rescission supports fuels management, but its 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." That is not a fringe finding. It is the agency's own language. The Tonto National Forest, where I ride, sits in fire-prone country, and I have no interest in seeing ignition risk climb because roads were pushed into areas that are currently protected. The agency must reconcile this proposal 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, and explain why this proposal departs from those prior findings. The economics do not support rescission, and the agency's own analysis makes that plain. The record shows that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that, the agency's cost-benefit analysis projects only $5.2 to $11.4 million a year in timber revenue to the Forest Service, while projecting recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. An analysis that cannot establish a net benefit is not a basis for policy. And this is before accounting for the existing $6.9 billion maintenance backlog on roads already built. How does expanding a road system that cannot be maintained serve the public interest? The agency should answer that question plainly. The legal history here matters too. The agency argues that state-by-state approaches can replace a national rule, but it already tried that and the courts rejected it. The record reflects that "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 Ninth Circuit found deficiencies in that state-by-state approach the last time it was tried. The agency has not explained how this proposal avoids the same problems, or addressed its own prior finding that local decision-making can incrementally erode nationally significant roadless values. That explanation is owed. On the question of statutory authority, the Tenth Circuit already ruled. Its holding was direct: "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 was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The agency must state, plainly and with legal basis, why it believes otherwise. I oppose this rescission. Rescind the proposal, not the rule. Sincerely, AJ Flint Mesa, AZ

I am a resident of Chandler, AZ, an avid hiker and amateur naturalist. The roadless areas nearest to me that I take advantage of are in the Tonto National Forest. I 100% support the maintaining (and even expanding) the Roadless Rule, and strongly oppose road construction and logging on the 58.5 million designated roadless acres of Forest Service land. Experts agree that roadless areas protect wildlife habitat, biodiversity and migration corridors ( https://www.hcn.org/articles/utah-biodiversity-thrives-in-utahs-roadless-areas-rollback-threatens-at-risk/ ), help keep invasive species at bay, prevent pollution and soil erosion into streams and boost climate resilience. Research, contradicts the government’s claim that building more roads will help fight wildfires - A 2020 Forest Service study concluded, after nearly 20 years of monitoring data, that more roads do not lead to better forest health through increased fire-management activity. ( https://research.fs.usda.gov/treesearch/61251 ) The roadless rule is an ecological boon for Western U.S. landscapes, where most of the affected areas are located, as well as for any Westerners who enjoy outdoor recreation or live off the land. Do not roll back the roadless rule!

Hello. I am an engineer for the energy industry who (in addition to my engineering degree) also holds a degree in Wildlife Biology from a top agriculture University. In addition to my professional credentials, I have also contributed thousands of volunteer hours to the exploration & mapping of caves across the U.S., including those in the Grand Canyon NP, Mammoth Cave NP, Tonto National Forest, & Fern Cave Federal Wildlife Refuge. I have also volunteered as a citizen scientist assisting the collection of microbes caves. Those microbes are studied at top universities by labs focused on novel drug discovery, material science, & carbon sequestration. My recreational interests are extensive -- I cave, rock climb, backpack, day hike, overland/off-road, etc. throughout the United States. In the last 10 years, I have travelled to several dozen National Forests for these activities including the Chattahoochee NF, Bridger-Teton NF, Daniel Boone NF, Monongahela NF, Petrified Forest NF, & Shasta-Trinity NF. While doing so, I strive to shop locally, dine locally, & support the small rural towns. For me, the biggest draw to areas such as this is the remote & unbroken environment. As any wildlife biologist can attest, habitats change dramatically when the continuous forest is interrupted by open space such as those created by roads. Additionally, as any caver can attest, some of the most fragile ecosystems on the planet can be hiding in plain sight (often just under our feet). I am especially concerned about sedimentation caused by building roads & logging in areas that would have otherwise been roadless. Not only can such activities degrade drinking-water supplies on the surface, but it can also destroy underground conduits of water such as those found in karst landscapes. This impact wields a double-edged sword: both the humans & the habitats that are reliant on the underground water supply are jeopardized. This impact isn't limited to a few rural towns or scattered populations, either. Nearly 40% of the drinkable groundwater in the U.S. comes from karst aquifers! Professionally, I am no strange to Federal documentation. I frequently write supporting documents for nuclear power plants that are reviewed by the U.S. Nuclear Regulatory Commission. I draw upon this experience when I review the documentation "supporting" the proposal to rescind the Roadless Rule & I am deeply troubled by the gaps in supporting evidence as well as failures of adequate planning. Below is an example of such: The DEIS does not analyze a reasonable range of alternatives. The USFS states this itself: "The alternatives evaluated in detail in this DEIS focus on the geographic locations (boundaries) in roadless rulemaking" (DEIS p. 34). Alt. 1 retains the 2001 Rule's prohibitions; Alt. 2 removes them nationwide; Alt. 3 "would continue the existing Rule's exceptions and provides for locally led boundary modifications" (DEIS p. 35). No alternative analyzed in detail varies the prohibitions & exceptions themselves according to stated resource criteria. NEPA requires "a reasonable range of alternatives to the proposed agency action... that are technically and economically feasible, and meet the purpose and need of the proposal," 42 U.S.C. Sec. 4332(2)(C)(iii), & the DEIS cites the parallel requirement at 7CFR1b.7(h) on the same page where it describes its own range as boundary-focused. The rest of this comment is attached as a file because the online portal's character limit is preventing the discussion of the matter in full.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting has meant nature preservation to me for nearly all my life, as much as we can achieve it. Wild horses draw me into the backcountry too: we hike to explore on foot in a responsible way, seeking them out and watching them in their natural habitat. I have fished for years. These pursuits share a single condition: country that roads have not fragmented. I am still learning Horse Mesa on the Tonto National Forest in Arizona, still exploring its 9,146 acres, and that fact alone says something worth preserving. The rescission of the 2001 Roadless Area Conservation Rule proposed in Docket FS-2025-0001 would put that process of discovery, and the land that makes it possible, at genuine risk. I oppose the rescission and ask the agency to answer the specific questions below. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres. The agency's stated justification for opening those areas to roads includes wildfire and fuels management, but the agency's own record undermines that case. The 2001 rulemaking found that "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 animals I have hunted nearly all my life, and the wild horses I travel to watch, depend on country that stays intact. If roading that country raises fire risk by the agency's own measure, the justification collapses inward. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas and reconcile the rescission with the ignition data in DEIS Table 21, which the agency's own draft environmental impact statement reports as showing far higher fire density on roaded land than inside the affected roadless areas. The economic case is no stronger. The agency's 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." Against that marginal production, the agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. That range cannot establish a net benefit. The road system the agency proposes to expand already carries a $6.9 billion maintenance backlog. I ask that the agency reconcile those numbers publicly and explain how an action whose own analysis cannot confirm a positive return justifies adding to infrastructure the agency already cannot maintain. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. The Tenth Circuit reviewed that question and its holding speaks for itself: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held that it did not create de facto wilderness. The agency must address that holding directly and state on what basis, if any, it maintains a contrary legal position. Finally, the rule as written already contains the flexibility the agency says it lacks. The agency's own characterization of the rule notes 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)." Existing mineral leases and community wildfire protection are addressed within the rule's structure. The agency has not identified which specific permitting or administrative burdens fall outside those exceptions. It should do so, with specificity and quantification, before any rescission proceeds. Across the Southwestern region, 739 municipal water intakes sit in watersheds containing affected roadless areas. The stakes of this decision extend well beyond any single parcel. Horse Mesa is a place I am still learning. I intend to keep exploring it, responsibly, and I expect the agency to give these questions a substantive answer. Sincerely, Louis Chavez Gilbert, Arizona

Dear Director: On behalf of Gila County, Arizona, we appreciate the opportunity to comment on USDA's proposed rescission of the 2001 Roadless Area Conservation Rule. Gila County supports greater flexibility for local forest managers to address conditions on the ground, particularly where road improvements and active forest management are necessary to protect public safety. Gila County is home to extensive National Forest System lands, including the Tonto National Forest, so Forest Service decisions on roads, forest health, and access directly affect County residents. Two priorities stand out: emergency access across federal lands, and active forest management to reduce catastrophic wildfire risk. Public Safety and Forest Roads Gila County's mountainous terrain, wildfire exposure, and dispersed rural communities create significant challenges for fire suppression, emergency medical services, evacuation, and disaster response. Forest roads are critical public-safety infrastructure, not simply recreational amenities. Control Road (FSR 64) is a key corridor through the Tonto National Forest for residents, forest management, and emergency response. The Forest Service has previously funded improvements, and the County's long-term goal remains a paved Control Road. Because the road is on federal land and serves federal purposes, the Forest Service should have a significant role in bringing it to standard. Young Road (FSR 512/FH-12) presents an even more immediate need. Young is an isolated rural community surrounded by National Forest System lands, making reliable access essential for residents, emergency responders, and wildfire evacuation. The project is well advanced: ADOT's June 2026 Stage III estimate identifies 13.5 miles of paving, drainage, guardrail, and erosion-control improvements at the 60-percent design stage, at an estimated cost of approximately $25.1 million. Gila County urges USDA and the Forest Service to provide the federal funding necessary to move Young Road into construction. Forest Management Is Emergency Management For Gila County, forest management is emergency management. The 2021 Telegraph Fire burned more than 180,000 acres in Pinal and Gila Counties. Severe wildfire destabilizes soils and watersheds, leaving communities vulnerable to flash flooding and debris flows long after the fire is out. In September 2025, exceptionally intense rainfall caused catastrophic flooding in the Globe-Miami area. Pinal Creek rose approximately six feet in 30 minutes; floodwaters damaged businesses and infrastructure, swept away vehicles, and three lives were lost. Gila County therefore supports giving local Forest Service officials sufficient flexibility to undertake hazardous-fuels reduction, thinning, prescribed fire, fuel breaks, and watershed restoration. Roads needed to conduct those treatments and provide suppression and emergency access must be part of that strategy. Federal Lands Require Federal Investment Gila County recognizes the values protected by the National Forest System. Rescission of the Roadless Rule would not itself authorize individual projects; forest plans, environmental review, and other federal requirements would continue to apply. Gila County and the Tonto National Forest already operate under a Cooperative Forest Road Agreement covering the planning, construction, and maintenance of forest roads. But federal responsibility should be accompanied by federal investment. A rural county should not bear the primary financial burden of improving Forest Service roads needed to manage federal lands, protect communities, provide emergency access, and respond to wildfires. Accordingly, Gila County supports greater flexibility to address local forest-management and transportation needs while retaining applicable environmental review. The County urges the Forest Service to use that flexibility to improve public safety and actively manage forests, and to invest in the infrastructure to do so, including federal funding to pave Control Road/FSR 64 and to move Young Road/FSR 512 from design into construction. These roads are on federal land and serve federal as well as local purposes; the federal government should be a principal partner in bringing them to the standard both the National Forest System and surrounding communities require. Gila County looks forward to continuing its partnership with USDA and the Tonto National Forest. Thank you for your consideration of these comments.

As a US citizen and resident of a small town in Arizona bordering Tonto national forest, I beg you to not get rid of the roadless rule. Please protect nature, God's creation. It's not undeveloped land. It is nature. We are part of an ecosystem that we require to survive. Please don't make us lose the beautiful world we've been given. As a citizen in a democratic country, I ask that my voice be heard: protect the roadless rule at all costs.

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

To Whom it May Concern, I am writing as a concerned citizen, professor at Arizona State University, and frequent hiker in wilderness areas, to strongly oppose the recision of the 2001 Roadless Rule. As an educator, I submit these comments because the record of policy reversals is itself a record students will one day read, and the Department owes that future readership something more than administrative convenience dressed as regulatory reform. The devastation caused by the 2020 Bush Fire in the Tonto NF, caused by a vehicle malfunction, and resulting in 193,455 acres burned, will, it's immediately obvious, take this area generations to recover. Hiking in nearby roadless areas such as the Sycamore Trail and the Denton Trail, to say nothing of the Arizona Trail in the Boulder Roadless Area make it abundantly clear how this irreplaceable wilderness would be at even greater risk from the effects of road building. Likewise the nearby Lime Creek Roadless Area would be jeopardized. My wife and I have hiked into this backcountry area twice in the last five years. Its remoteness is a blessing for the fauna and the flora to say nothing of the people who pass through it. Any road-building would greatly increase the already very real wildfire danger, especially with the drought conditions we've had recently. More to the point, the evidence strongly contradicts the government's claims that rescinding the Roadless area rule will reduce wildfire risk. More particularly: 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). Wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). For human-caused, natural, and undetermined fires, wildfire-ignition density decreased as distance to road increased: in lands between 0 and 250 m from roads, 6 fires ignited per 1000 ha, whereas fewer than 2 fires ignited per 1000 ha at a distance class of over 2000 m from roads. — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Moreover, currently, forty percent of lands within inventoried roadless areas have a high or very-high wildfire hazard potential, ranging from 5 percent in the Eastern Region to 60 percent in California. About 23 percent (10.2 million acres) of inventoried roadless areas managed under the 2001 Roadless Rule are within the wildland-urban interface (WUI), areas where human development intermixes with the wildland, based on the definition of WUI set out in the Healthy Forests Restoration Act of 2003. — Department of Agriculture, Forest Service, 2025 (https://www.federalregister.gov/documents/2025/08/29/2025-16581/special-areas-roadless-area-conservation-national-forest-system-lands) Also, wildfires are almost twice as likely to occur in roaded areas as in roadless areas, because roadless areas are generally located further away from communities and are harder to access — U.S. Senate, 2025 (https://www.congress.gov/bill/119th-congress/senate-bill/2042/text) Aside from the increased wildfire danger the rescission would cause, the effects on the native ecosystems would be grievous. For instance, road networks are a common disturbance on the landscapes that cause habitat fragmentation and create edges with high resource availability that can act as important channels for the spread of invasive alien plants in various habitats, including nature reserves. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Dai et al., 2025 (https://doi.org/10.1111/ddi.70002) More particularly, in the Boulder Roadless Area, the roadless condition is fundamental to preserving wilderness and recreation. Maintained trails remain free from motorized competition; fishing streams flow through undisturbed watersheds; paddling on Sycamore Creek and Canyon Lake occurs without road-related erosion or sedimentation; etc. Road construction would fragment wildlife habitat, increase erosion into fisheries, introduce motorized noise to backcountry trails, and degrade the primitive character that draws hikers here. In conclusion, I plead with you for the good of us all and not just the few who stand to profit, not to proceed with the rescission of the Roadless area rule. Sincerely, Christopher D. Johnson CommentID: RLC-20261005-GYX9A0

I am an Arizonan and I recreate on public land almost daily. Public lands are central to the lifestyle and traditions that citizens like myself deeply value as Americans. I recreate on the Coconino NF, Kaibab NF, Tonto NF, Coronado NF, Prescott NF and the Apache Sitgreaves NF. I am an angler, hunter, backpacker, archer, recreationist, and roadless areas are central to my way of life. It is imperative that backcountry areas are conserved for my children's generation and for generations to come. As a scientist, I believe that the rationale behind rescinding the roadless rule is built on faulty logic and poor presumptions instead of evidence. The rescission of the Roadless Rule is dangerous and not backed by solid science. The benefits of the Roadless Rule as they are written protect wildlife, watersheds, ensure proper wildfire management, protect clean water while providing the flexibility land managers need. The Roadless Rule does not limit active forest management. Land managers are able to treat high fuels areas while preventing the construction of permanent roads. The data clearly show that wildfire risk increases in areas with roads. I support scientifically informed forest management from local experts who understand the impacts of recreation and forest health. Eliminating the Roadless Rule is dangerous and puts our forests, citizens, wildlife and firefighters at greater risk. In Arizona, wildfire ignitions are nearly seven times more likely near roads according to a report from The Wilderness Society. Introducing new road systems will increase fire frequency and put our fire fighters in harms way. The impact of rescinding the Roadless Rule will affect 45 million acres of land while federal land management agencies remain underfunded and understaffed. This proposal is being made while the Forest Service is experiencing a major reorganization including the elimination of regional offices, relocation of staff and a reduction in force. How does removing long-standing protections amid a major agency restructuring benefit the American people and the lands we all share? It does not. Thank you for the opportunity to comment on the Roadless Rule.

Public Comment Opposing the Proposed Rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001, RIN 0596-AD66) Dear Director, Ecosystem Management Coordination, I am writing to voice my firm opposition to the U.S. Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule. I advocate for the permanent preservation of all 44.7 million acres of Inventoried Roadless Areas (IRAs) nationwide. The current federal baseline ensures a unified, robust standard of ecological integrity that localized forest plans simply cannot replicate. While I care about the protection of all national forests across every state, this proposal strikes incredibly close to home. I live in Arizona, where I have hiked and backpacked through the Tonto National Forest and around Mount Lemmon in the Coronado National Forest numerous times. I know firsthand how vital these unroaded spaces are to preserving the delicate desert-to-mountain ecosystems, protecting local municipal watersheds, and offering wild landscapes for quiet recreation. If the Roadless Rule is rescinded, the iconic backdrops of the Arizona National Scenic Trail which winds directly through IRAs in these forests could be forever scarred by industrial road construction and commercial logging. Furthermore, my personal connection to our national forests spans the country. I have had the privilege of creating beautiful memories hiking in the Deschutes National Forest in Oregon, the George Washington National Forest in Virginia, and public lands near Ogden, Utah. Most deeply, I proposed to the love of my life in the Snoqualmie National Forest in Washington. These are not merely administrative parcels of land to be exploited; they are the irreplaceable geography of our lives. The impacts of this rescission also extend directly to my loved ones. I have family and friends who rely on the intact backcountries of Washington and Montana for hiking, hunting, and fishing. Millions of outdoor enthusiasts depend on the primitive habitats protected by the 2001 Rule to maintain healthy big game populations and native trout streams. I strongly reject the agency's primary justification that rescission is required for localized forest management, and I urge you to consider the following substantive points regarding wildfire and watershed degradation: - Increased Wildfire Risk and Human-Caused Ignitions: The Forest Service's own DEIS data confirms that repealing the 2001 Roadless Rule actually increases the probability and frequency of wildfire ignitions. Historically, inventoried roadless tracts have up to four times fewer wildfire starts than heavily roaded forest areas. Carving new road networks into remote backcountry provides vehicle access that introduces a primary source of human-caused ignitions. Furthermore, commercial logging operations open up the canopy, altering local microclimates by drying out understory vegetation, creating wind tunnels that accelerate fire spread, and introducing highly combustible fine fuels. - Severe Degradation of Watersheds and Drinking Water Resources: Roadless areas safeguard the headwaters of vital municipal watersheds that provide clean, unfiltered drinking water to over 25 to 60 million Americans. Roads inherently disrupt natural hydrology. Constructing new roads, culverts, and stream crossings triggers severe soil erosion and mass wasting events. The resulting sedimentation and toxic runoff empty directly into pristine headwater streams, choking aquatic habitats, decimating native trout and salmon spawning grounds, and threatening down-river municipal water supplies. This structural damage will force local communities to bear millions of dollars in skyrocketing water treatment and infrastructure costs. The Forest Service already possesses the administrative flexibility under the 2001 Rule to execute targeted hazardous fuel reductions and handle emergencies without stripping protection from 44.7 million acres of pristine public land. Adding more roads when the agency already faces an $8.6 billion deferred road maintenance backlog is environmentally and fiscally irresponsible. Our national forests are an interconnected legacy belonging to all Americans and future generations. I urge the U.S. Forest Service to reject the proposed rescission and maintain the 2001 Roadless Area Conservation Rule in its entirety. Sincerely, James Le Gilbert, AZ 85296

October 2, 2026 Director, Ecosystem Management Coordination USDA Forest Service 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 Re: Docket FS-2025-0001, Special Areas; Roadless Area Conservation, Draft Environmental Impact Statement. Comment in opposition to rescission; support for Alternative 1 (No Action) Dear Director: I oppose the proposal to rescind the Roadless Area Conservation Rule, and I urge the Forest Service to select Alternative 1, the No Action alternative, in Docket FS-2025-0001. I live in Las Vegas and spend a large part of every year backpacking, hiking and occasionally rappelling in remote country across the western United States. I am a user of the backcountry, not a visitor to its trailheads, and the experience I value most is the one roadless land exists to protect: a place with no motor vehicle noise, no sign of other people, and a view of land that looks as it did centuries ago. That experience is rare and cannot be rebuilt. In Washington I hiked 20 miles into the Olympic wilderness and looked out over untouched country to the horizon. In Idaho's Sawtooth range I hiked deep into old-growth forest and slept under skies with no light pollution. Idaho has its own roadless rule, which this proposal leaves in place, so I raise the Sawtooth only to show what intact backcountry offers. I am asking that the same protection stay in place in the states where it is now at risk. Those states include the places I visit most. In Arizona, the Arizona National Scenic Trail crosses the Mazatzal and Boulder roadless areas of the Tonto National Forest, part of roughly 1.17 million acres of inventoried roadless land in the state. Near my home, Nevada has more than 3 million acres of inventoried roadless land across the Humboldt-Toiyabe and Inyo National Forests and the Spring Mountains National Recreation Area. In Washington, roadless lands on the Olympic National Forest border the park and shelter salmon spawning habitat. In Utah, about 4 million acres of national forest would lose protection. A road, a clear-cut or a mine ends solitude and quiet for every later visitor, and no restoration brings them back. The Draft EIS does not justify that loss, for these reasons. Roads increase wildfire ignitions. Research in Fire Ecology found that fires are about four times more likely to start near a road than in a roadless area, and the agency's own analysis acknowledges that human-caused wildfires could become more frequent if roads open this terrain to vehicles and campfires. The rescission would add ignition sources to remote forest where fire response is slowest. The benefit is small and the cost is large. As reported from the agency's own figures, rescission would raise national timber harvest by only about 5 to 10 percent, while the Forest Service already carries a road maintenance backlog of billions of dollars. Adding roads to the least accessible land in the system adds to a bill the agency cannot pay. The Final EIS should weigh that cost against the recreation economy that depends on undeveloped backcountry. Wildlife and water depend on intact habitat. Roadless areas provide core habitat and connecting corridors, and road construction is a leading source of sediment in streams. The Final EIS should state the effect on threatened and endangered species and on salmon streams, area by area. The public process is too short. The comment period is a fraction of the time the 2001 rule received, and the Draft EIS concedes that full rescission carries the greatest potential for adverse effects on Tribal rights and interests. The 2001 rule has worked for 25 years and still leaves room for fire management and local decisions. I ask the Forest Service to retain it, to select Alternative 1, and to respond in the Final EIS to the specific concerns above. Respectfully, Avid Outdoorsman

This comment is to note opposition to the 2001 Roadless Rule Rescission being proposed by the Forest Service. I advocate personally for any and all wilderness and Roadless areas but the Olympic Penninsula of Washington state is my favorite and the place where my love of wilderness began. I explored the now in jeopardy of logging Jupiter Ridge climbing Mt Jupiter with my father in 1976. Another nearby mon- protected area is Lena Lake which is an absolute jewel. Other equally valuable areas to protect that I have visited are the Tongass Nat'l. Forest of Alaska as well as Mt Hood area in Oregon and Tonto National Forest of Arizona. Their value as sources of clean air and water, critical carbon storage, habitats for intact eco-systems as well opportunities for recreation for current as well as future generations far out-weigh the short sighted gains that would be obtained with resource extraction. I would like to close with a quote from the great American author Wallace Stegner. "Something will have gone out of us as a people if we ever let the remaining wilderness be destroyed; if we permit the last virgin forests to be turned into comic books and plastic cigarette cases; if we drive the few remaining members of the wild species into zoos or to extinction; if we pollute the last clean air and dirty the last clean streams AND PUSH OUR PAVED ROADS THROUGH THE LAST OF THE SILENCE; so that never again will Americans be free in their own country from the noise, the exhausts, the stinks of human and automobile waste". - Wallace Stegner

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Tonto National Forest is some of my favorite land in Arizona. I hike and trail run throughout it, across places like the Goldfield, Black Cross, Horse Mesa, Boulder, Lime Creek, and Salome roadless areas, and I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule. What we have is not easily replaced. Once roads go in, the land changes, and that change does not reverse. It is only after we have destroyed so much of the natural beauty of this Earth that we realize what a huge mistake we have made, and there will be no going back. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres. The areas I named inside the Tonto alone span tens of thousands of acres across a desert landscape where water, wildlife, and quiet backcountry are already under pressure from a growing population. Rescinding the national rule puts all of that at greater risk, and the agency's own record makes the case against doing so. On wildfire, the agency states in its own documents: "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 nonetheless justifies rescission partly on fuels and fire management grounds. The agency cannot simultaneously hold this finding in its record and use fire as a reason to open roadless areas. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The agency has also tried this before. Its own record reflects that "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 Ninth Circuit has already reviewed what happens when the national rule is replaced with a state-by-state approach, and the outcome was not favorable to the agency. The Tonto's roadless areas deserve the same protection every comparable forest receives, not a patchwork that varies by political will in any given administration. The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the legal deficiencies the court identified the last time this was attempted. Across the Southwestern region, which includes Arizona, 739 municipal water intakes sit in watersheds containing affected roadless areas. Opening those watersheds to road construction is not an abstraction. The people who depend on water flowing out of the Tonto's roadless drainages have a concrete stake in this rule, and so do the outfitters, guides, and tour operators whose businesses depend on the quality of the backcountry experience those areas provide. Yet the proposal's regulatory flexibility analysis reaches a no-significant-impact conclusion by spreading projected losses across every small firm in the sector nationally, rather than examining the businesses actually holding permits in the affected areas. The agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That loss does not fall on an abstraction. It falls on specific permit holders operating in specific places. The agency should withdraw the small-entity certification and conduct the analysis at the level of the firms that will actually feel the impact. Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" and then weighs none of them. This comment is one such interest. People who have planned their recreation, their businesses, and their relationship to public land around the protections the 2001 rule provides deserve more than an open question in the Federal Register. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it finalizes any action. The Tonto is irreplaceable. Protect it. Sincerely, Caitlin Jahnz Phoenix AZ

I completely and whole-heartedly opposed to the idea of rescinding the Roadless Rule. As someone who lives in Phoenix, AZ, over the years I have watched my city become further urbanized, watching natural desert turn into warehouses and concrete spaces. It has given me nothing but tremendous appreciation for the wilderness every time I am able to be in a forested space. I have been fortunate enough to hike in Tonto National Forest, an area that is partially covered by the Roadless Rule. Witnessing breathtaking nature emphasized to me that the land’s beauty was because it was as intact as possible, which would be lost in repealing this rule. The roadless rule has been in place for 25 years allowing irreplaceable ecosystems in OUR public lands to thrive The current administration has recently been proven to prioritize legislation in favor of advancing mining, oil/gas drilling, repealing protections for endangered species. As recently as September 5, the grey wolf and the Mexican wolf have been victims of harmful environmental legislation as seen in an executive order signed by Trump to remove their endangered species protection. In March 14 of this year, Trump also signed an executive order allowing for oil drilling in the state of California. Rescinding the Roadless Rule will only increase the ability to access these areas and orchestrate more harm. Allowing roads, construction, and timber harvest, would threaten habitats, air quality, clean water sources, and our own recreational opportunities in these beautiful outdoor spaces. One of the claims from those favoring this rule be rescinded is that it will reduce forest fires and make them more manageable, yet 120 current and former firefighters in association with the Wildland Firefighters wrote in an open letter to congress disagreeing with these beliefs. According to them, “The bottom line is that allowing new road-building and more logging in roadless areas will increase the number of fire ignitions in remote and steep terrain... increase firefighter exposure to hazardous suppression efforts with low probabilities of success and pull scarce resources away from the priority of protecting communities.” Studies conducted by Gregory H. Aplet, Phil Hartger, and Matthew S. Dietz, found that “from 1994-2024 in all 8 contiguous-US Forest Service regions combined, wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha).” These are quotes coming from expert studies solidifying the call to protect these lands, not open them up. Experts, nature enthusiasts, outdoor recreationalists, and community members all agree that these lands are our national treasure and it is our responsibility as citizens to give them their best chance to not only survive, but thrive.

Dear Doug Burgum , Donald Trump and the Forest Service, I do not understand why you would rescind the roadless rule, and I adamantly oppose any changes to this policy. It will only increase fires and disturb an already fragile environment in which I live! And who speaks for the animals and trees that dismantling this policy will kill and destroy? I know I do and I know my senators do and I know most Americans also oppose cancelling this rule. Is nothing sacred to you? You who are reading this? I live next to the trees and so much wildlife great and small - our national forests and parks are treasures and honestly American’s best idea. Let’s keep it as such and treat them with respect- not as commodities to rape and destroy and mine. Rescinding the roadless rule in place since 2001 is costly and one of the last refuges for water and wildlife and any actions to undo this rule is criminal and will be see as such. The Forest Service already manages a road system that is over seven times larger than the Interstate Highway System! Should taxpayers be on the hook to build more expensive roads that damage our water, wildlife, and outdoors? And you’ve already cut the forest service back to a level that is unsustainable. Gutting this rule without public meetings - all over the country is cowardly and wrong. Let the people speak and not those in concrete slabs. I border the Tonto National Forest and it deserves to be protected. America’s National Parks and Forests and Monuments are our parks, monuments and forests. They deserve better than bulldozers, and so do we. ‘The care of the Earth is our most ancient and most worthy, and after all our most pleasing responsibility. To cherish what remains of it and to foster its renewal is our only hope.’ Wendell Berry

To who it may concern, I believe that creating easier ways to get deep into the forests will ultimately create longtm term issues in the following areas: 1. More campers will create more trash in remote areas, especially along waterways and lakes (I have a truck bed full of trash from labor day campers after just a few hours pick up) more habitat destruction, (from utv, atvs and vehicles), wildfires that are harder to fight and people getting lost and dying in remote areas. While we do need to figure out more lumber sources, and many areas could stand some thinning, turning it over to private commercial companies (unless there's major forestry oversight) will end in loss that will take centuries to repair. This is a shortsighted idea at best. I like in the middle of the tonto national forest, I've hiked it in all directions, I grew up here and it's my home, I'd hate to lose more pristine forest to muddy roads with hundreds of trash filled campsites. Few respect the forest while camping and hiking, this rescinding will make it easy for the disrespectful to do more damage. It's disgusting to go hiking just to pick up dental picks, beer cans and broken outdoor equipment.

To the United States Department of Agriculture, My name is Dakota. I am a natural born United States citizen and I believe rescinding the Roadless Rule would negatively impact the wellbeing and future of this nation far more than it would benefit. I was born in Colorado, near the Rocky Mountains. As a young child my family and myself moved to Arizona. The national parks and wildlife of that state is among the most beautiful this world has to offer. Beyond that, access to these places was a key factor in my young self developing a love of the outdoors of our beautiful country. The culture and community we see throughout the United States is underpinned by these diverse and healthy ecosystems. More practically, the National Parks of my home state are a boon for revenue. In 2024 alone the state brought in $1.4 Billion just through national parks visits. From the Grand Canyon, to the Sonoran Desert, Tonto National Forest and more, the diverse and expansive parks of Arizona help balance our carbon emissions making for a cleaner and healthier state. Rising temperatures are especially dangerous in arid places such as Arizona. Our national parks help protect and preserve our state as a growing destination for families to call home. The Roadless Rule is a key factor in protecting our home. Easing these protections and allowing interested bodies to alter these natural spaces not only will hurt our ecosystems, but our economy as well. I am strongly against rescinding the Roadless Rule. Thank you.

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.