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I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I am a resident of Utah living near and regularly recreating in the Wasatch National Forest and the Uinta National Forest. I also deeply care about the ecological impacts of this rule, specifically in the Tongass National Forest in Alaska. The DEIS removes protections from every one of these landscapes without analyzing the site-specific consequences for any of them. As a regular user of Utah’s public lands and a citizen invested in our nation's foundational ecological treasures, I am providing this comment as record evidence that localized, site-specific analysis was owed and legally deficient under the National Environmental Policy Act (NEPA). I urge the agency to reject the proposed action based on the following critical flaws: 1. Failure to Analyze Site-Specific Consequences (Tongass, Wasatch, and Uinta National Forests) The DEIS completely fails this standard across my most cherished distinct ecosystems: The Tongass National Forest: Removing the Roadless Rule jeopardizes 9.3 million acres of the world’s largest remaining temperate rainforest, opening it to aggressive road building and industrial logging. This action directly targets rare, ancient old-growth Sitka spruce stands for clearcutting. Building roads here will degrade world-class salmon spawning habitats through toxic road runoff and massive sedimentation, while driving the endemic Alexander Archipelago wolf closer to extinction. The Wasatch and Uinta National Forests: In my home state of Utah, these forests protect steep, fragile mountain watersheds. Stripping roadless protections here opens vulnerable backcountry slopes to localized fragmentation, destroying the exact wild characteristics that millions of Utahns rely on for outdoor recreation and ecological stability. 2. Pretextual Purpose and Need The stated purpose and need for this action is fundamentally flawed. It is explicitly framed around reducing regulatory burdens and returning decision-making to local officials—not forest health or wildfire mitigation. The agency’s bias is laid bare by its elimination of every single conservation-oriented alternative. The DEIS openly admits that preserving more acreage "would not be responsive to the deregulatory executive orders," and goes so far as to eliminate a viable option simply because analyzing roadless values presents "an administrative and legal burden for the agency." Furthermore, the agency’s own words expose that this rule change offers no proactive stewardship, stating: "This proposed rescission does not mandate timber cutting or road construction." No management benefits or health outcomes are promised; the agency is merely stripping a foundational environmental protection to satisfy an administrative checklist. 3. Proximity of Roads Linearly Correlates to Increased Wildfire Risk (DEIS Table 21) The agency’s own data from 2014 to 2024 completely refutes any narrative that road building aids fire management. Human-caused ignitions run at 22.4 per million acres per year on national forest land, compared to a mere 3.0 ignitions inside protected roadless areas—a 7.5x increase where roads exist. The DEIS rightly concludes that "human-caused ignitions increase in abundance with proximity to roads." The effects analysis clearly concedes that increasing road access will increase the overall number and frequency of wildfires, directly endangering nearby rural communities and over-allocating strained fire suppression resources. This is an unacceptable liability for communities flanking the Wasatch and Uinta fronts. 4. Severe Economic Deficit and Infrastructure Backlog (DEIS Economics & Infrastructure Analysis) The Forest Service cannot safely maintain the infrastructure it already owns. Regular road appropriations collapsed from 234 million in 2004 to just $73 million in 2024, leaving the agency with a staggering 6.9 billion deferred maintenance backlog. The agency’s own Cost-Benefit Analysis shows that the math cannot clear zero. The agency's accounting concludes that the total net present value of this action runs as low as negative 92 million. The DEIS openly admits that overall road mileage, deferred maintenance, and long-term management costs are all likely to increase under this proposal. It is fiscally irresponsible to build new, high-liability roads while drowning in billions of dollars of unaddressed maintenance on existing routes. Because the Forest Service has failed to analyze the localized, site-specific destruction that logging roads would bring to the backcountry areas of the Tongass, Wasatch, and Uinta National Forests, and because its own internal data shows this action will increase fire risks, harm water quality, and worsen a multi-billion-dollar infrastructure deficit, I strongly oppose the rescission. The agency must maintain full, nationwide protections under the 2001 Roadless Rule.

The Wasatch and Uinta mountains are where I hike and camp, and protecting those places is exactly why I am filing this comment. Mill Creek Canyon in the Uinta National Forest, White Pine and Twin Peaks in the Wasatch-Cache National Forest, these are the wild, unroaded landscapes I want my children and their children to be able to experience. The proposal before the agency would put all of that at risk, and the agency's own record makes clear it should not proceed. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres. These are not abstract acres. They are the backcountry I depend on, the places that are still genuinely wild precisely because roads have not reached them. More and more land is developed and destroyed, increasing fire risk, increasing watershed contamination, decreasing wildlife and plant populations. Rescinding the 2001 rule accelerates every one of those trends, and the agency's own analysis says so. On wildfire, the agency's record states plainly: "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 on fuels management grounds, which inverts what the agency's own findings show. I ask that the agency explain why the proposal departs from those prior findings and that it 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. Watersheds need to be kept pure. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. By the agency's own data, roads and their facilities contribute directly to contamination. The agency has acknowledged that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. How can that be justified when everyone needs access to clean water now more than ever? I want the agency to explain, specifically and on the record, how opening these watersheds to road construction serves the public interest in clean drinking water. The economic case for rescission is just as weak. The agency's own record acknowledges: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, and the road system already carries a $6.9 billion maintenance backlog. The agency cannot establish a net benefit from this action by its own numbers. It must reconcile the proposal with that analysis and explain what economic rationale remains. On the question of statutory authority, a court already answered it. 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 agency argues the 2001 rule exceeded its authority, but the Tenth Circuit found the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must state, plainly and with legal support, the basis for any position contrary to that holding. Finally, the proposal itself acknowledges that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them. The agency cannot ask the public to comment on consequences it has simultaneously placed outside the scope of its own analysis. The foreseeable plan-amendment scenario, including expanded timber harvest area, must be analyzed as part of this action, not deferred. We do not want more roads, development, mining, or logging on our public lands. These lands should be left as wild spaces and backcountry. The agency held more than 600 public meetings and received 1.6 million comments before it put the 2001 rule in place. It has held none to undo it. That process debt alone warrants withdrawal of this proposal. Sincerely, Michelle Richardson Sandy, Utah

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Uinta National Forest is not abstract wilderness to me. I have hiked and visited the lake there, and what I want for that land, and for public land generally, is simple: stop destroying our forests and harming the environment. We cannot keep doing it. That is the frame through which I read this proposal, and what I read concerns me. On water, the numbers the agency itself has compiled are striking. More than 7,000 municipal water intakes sit in watersheds fed by roadless areas, and roughly 24 million Americans drink water that begins there. Fewer than 12 percent of those watersheds have impaired streams today. The agency's own analysis shows that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I already know that a lot of people do not have reliable access to clean water. Putting sediment into those watersheds makes water unsafe to drink and use, and it costs a great deal of money to fix. What the agency has not explained is how rescinding the rule that protects the source watersheds is consistent with keeping that sediment load low. I ask that the agency address this directly, with specific reference to how the proposal accounts for increased sedimentation risk to drinking water supplies currently protected under the 2001 rule. On wildfire, 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 in part on fuels and fire management grounds. That justification runs directly against the finding just quoted. I ask that the agency explain on the record why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it 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. On economics, the agency's 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 projected timber revenue to the Forest Service of $5.2 to $11.4 million a year, the agency's own cost-benefit analysis projects recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency's road maintenance backlog already stands at $6.9 billion. How does expanding a road system carrying that backlog, for a commodity contribution the agency itself measures in fractions of a percent, constitute sound management of public land? On the legal record, the agency now argues that the 2001 rule exceeded its statutory authority. The courts that reviewed that question disagreed. 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." That court found the 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not treat it as creating de facto wilderness. The agency has not explained what has changed in the governing law. I ask that it do so. Finally, on the state-by-state approach the proposal advances as an alternative, the agency's own record already 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 Ninth Circuit examined the last attempt to replace the national rule with state petitions and found it deficient. The agency must address how this proposal avoids those same deficiencies, and must acknowledge its own prior finding that incremental local decision-making erodes nationally significant roadless values over time. I am asking the agency to deny this rescission and to keep the 2001 Roadless Area Conservation Rule in place. Sincerely, Neil Raman Salt Lake City, UT

I firmly oppose USDA’s plan to rescind the 2001 Roadless Rule. These roadless national forests are some of the last untouched public forest landscapes remaining. They are crucial for clean drinking water, wildlife habitats, salmon streams, old growth forests, outdoor recreation, and serve as vital spaces for communities, Tribal Nations, and future generations. Once split by roads, logging, and industrial access, the harm is irreversible. USDA must not take away a national safeguard that has protected these forests for over two decades. The current Roadless Rule already permits necessary activities to mitigate wildfire risk, so repealing it isn’t required for community safety. In fact, more roads increase human ignition risks, habitat fragmentation, erosion, and long-term management expenses. I’m also worried that removing the rule would transfer protection decisions to local forest planning, making intact forests more susceptible to political influence and short-term exploitation. Public forests should be managed for clean water, biodiversity, climate resilience, Indigenous stewardship, and public welfare, rather than opening them to more roadbuilding and logging. I live in Utah and the Wastach-Cache-Uinta National Forest is my backyard. We don’t want the Roadless Rule repealed here, or anywhere. Please retract the proposed rescission, maintain the 2001 Roadless Rule, and choose the strongest option to safeguard roadless areas throughout the National Forest System. Thank you for considering my input.

Dear USDA Forest Service Planning Team, I am commenting to express that I strongly oppose the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule, and I urge the U.S. Forest Service to select Alternative 1 (the 'No Action' Alternative) to keep all protections in place. I have spent a great deal of time in various areas currently protected under the National Roadless Rule, including but not limited to Green Mountain National Forest, White Mountain National Forest, Allegheny National Forest, Monongahela National Forest, Dixie National Forest, Uinta National Forest, as well as Pike, San Isabel, Gunnison and White River National Forests protected under the Colorado Roadless Rule. In these places I have met and lived with people who are dependent on the preservation of this rule- whether they rely on local watersheds for drinking water (roadless areas protect critical municipal water sources and drinking water for more than 60 million Americans across dozens of states), or whether they recreate like myself (hike, fish, hunt, camp, or mountain bike), or rely on the preservation of lands for that recreation to sustain their employment and local economy in specific inventoried roadless areas (IRAs). All of this of course, and still yet to mention the catastrophic impact rolling back this rule would have on habitat and wildlife, old growth and climate. Because the existing rule already permits necessary management and emergency fire response, opening 58.5 million acres to new commercial logging, mining, and road construction is unnecessary and harmful. Please preserve the 2001 Roadless Rule in its entirety. Sincerely, Lisa (Bolduc) Bobowicz East Aurora, New York

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas of Utah are not abstractions to me. I hike and camp all throughout the wilderness here, and I hold a deep conviction that the natural life in these places deserves to remain undisturbed and quiet. I paddle in Fish Lake, Manti, the Uintah national forest including Heber, and many more. I ride trails all throughout the Uinta National Forest, especially near Payson Canyon. The Roadless Area Conservation Rule is the legal backbone that makes these experiences possible, and the proposal to rescind it, Docket FS-2025-0001, would do irreversible harm to places I know and care about. The North Peak roadless area in the Uinta National Forest covers 15,673 acres, and I camp there multiple weeks throughout the year. I have watched that area carry the scars of wildfire, and the connection between road access and fire risk is not speculative. 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 DEIS reinforces this with ignition data: "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." Given that the proposal justifies rescission partly on wildfire and fuels management grounds, I ask that the agency explain why it departs from these prior findings, and that it quantify the expected increase in human-caused ignitions from new road access and weigh that increase honestly against any claimed reduction in wildfire hazard. The Haystack Hill roadless area, 6,255 acres in the Uinta National Forest, is a place I return to many times throughout the year. The canyon is already heavily traveled along the roads that exist. Opening more roads does not serve recreation or quiet; it opens the door to extraction that degrades the landscape. That concern extends across all six of the inventoried roadless areas I am writing about: Levan Peak at 22,092 acres in the Manti-La Sal National Forest, Sanpitch at 29,129 acres in the Manti-La Sal, Oak Creek at 54,053 acres in the Fishlake National Forest, and Big Horseshoe at 17,557 acres in the Manti-La Sal. Hiking Big Baldy in the Sanpitch area was an important part of my experience growing up, and the current rule is what I have relied on to know that area would be maintained. Camping near Oak Creek, the quiet of it, matters to me. The Big Horseshoe trail is absolutely gorgeous and needs to be preserved. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres, and the rescission places all of it at risk from decisions made area by area without the structural protection the rule provides. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. That omission is not a procedural nicety. Under established administrative law, an agency changing course must identify and genuinely assess the reliance interests its prior policy created. This comment is one such interest. The agency must identify and weigh the reliance interests described in the comments it receives, including mine, before it proceeds further. The regulatory flexibility analysis reaches its no-significant-impact conclusion by spreading losses across every small firm in the sector nationally, rather than examining the outfitters, guides, and tour operators who actually hold permits in the affected areas. The DEIS names those operators as affected parties, and the agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million per year. A certification of no significant impact on small entities cannot survive that contradiction. The agency should withdraw that certification and replace it with an analysis focused on the small entities actually operating in these roadless areas, not a national average that dilutes the real harm. The Manti-La Sal and Uinta watersheds that sustain these places are not isolated from communities downstream. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. Road construction disturbs soil and increases sedimentation in ways that the current rule was designed to prevent, and the rescission creates no substitute protection. The agency has not demonstrated that downstream water quality will be adequately safeguarded, and it should be required to say plainly how it will be. Sincerely, Nathan Jones Spanish Fork, Utah

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Cache National Forest is my backyard. I hike throughout Utah, but the mountains above Cache County are where I find quiet, photograph clear mountain streams and high ridgelines with no visible sign of human impact, where wild animals still gather and thrive away from modern development and machines. Cutler Marsh in Cache County is where I paddle, fed by the Logan River and the Blacksmith Fork River, both of which have their headwaters in Cache National Forest, and by the Bear River, with headwaters in the Uinta National Forest. The water quality in that marsh begins in these roadless areas. I oppose the rescission of the 2001 Roadless Area Conservation Rule as proposed in Docket FS-2025-0001. I serve as the Cache County Trails and Active Transportation Coordinator. In that role I have seen what good local/federal partnership looks like. In the Wellsville Mountains, 1,717 acres in the Wasatch-Cache National Forest, I spent years working on a project with the county to open additional access for hikers, campers, and horseback riders through a new trailhead. Access into those mountains is not a federal problem. This should be a local-led effort and we have made big strides locally with Forest Service support and without touching the roadless character of the land. Around Clarkston Mountain, 7,099 acres in the Caribou National Forest, I have been working to preserve existing roads already in the area. With those existing roads preserved there will be plenty of access and recreation opportunities with no need to impact or change the existing roadless portions. The Mt. Logan roadless area is different in what would be lost. I have been hiking in and around Mt. Logan South (17,014 acres), Mt. Logan North (18,930 acres), and Mt. Logan West (5,285 acres), all in the Wasatch-Cache National Forest, for almost 8 years. I have spent many Saturdays maintaining trails and helping people with disabilities get out and enjoy them. I have seen all kinds of wildlife who still call this yet unfragmented place home. To the south of this area there is already land crisscrossed with roads, and hiking there is a very different experience, with less diversity in the animals you are likely to see and the constant noise of machines. It makes sense to allow different areas to serve different recreation and access needs rather than making the whole of our wild lands look and feel the same. The agency's own record makes this concern concrete. Its draft environmental impact statement 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 nonetheless justifies rescission partly on wildfire and fuels management grounds. I ask that the agency reconcile this contradiction: explain specifically why the proposal departs from its own prior findings on fire occurrence, and reconcile the rescission with the ignition data in its own DEIS, which reports higher fire density on roaded land than inside the affected roadless areas. The proposal overstates what the rule prohibits. The agency's own text notes that the rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If the justification for rescission is permitting burden and administrative difficulty, I ask that the agency identify which burdens are not already addressed by those existing exceptions and quantify those burdens with specificity on the record. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres. Across the Intermountain region, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The proposed rescission's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year, yet the regulatory flexibility analysis certifies no significant impact on small entities by averaging that loss across every small firm in the sector nationally rather than examining the outfitters, guides, and tour operators actually holding permits in these areas. I ask that the agency withdraw that certification and assess impacts on the specific small entities operating in potentially affected roadless areas. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My work coordinating trails and access in Cache County, the public investment in the Wellsville trailhead, and the years of volunteer trail maintenance in the Mt. Logan roadless areas rested on the assumption this rule would hold. Sincerely, Landis Wenger Logan, Utah

As a researcher who studies forest ecology, it is vitally important that we limit the amount of fragmentation that occurs in these forests to increase the resilience and ecosystem services our national forests provide. From a citizens standpoint, I have been traveling the U.S. the past few months and have primarily visited national forests including the Ozark NF, Uinta NF, Boise NF, Willamette NF, and Sequoia NF. These are beautiful places that support beautiful and diverse ecosystems that are a treasure for all Americans. Please do not tarnish the beauty and ecology of these places by dismantling the Roadless Area Conservation Rule. We all benefit from this rule, even though the benefits may largely be indirect. We need to think about the sustainability of our public lands and keep this rule intact so future generations can have access to clean air, clean water, and beautiful places to recreate and research. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

My name is Blake. I hold an advanced education and work as a software engineering director. I'm also an avid hiker and lifelong camper who, until recently, lived right next to the Uinta National Forest. I care deeply about clean water and undisturbed wildlife habitats, and I urge USDA to withdraw this proposal and keep the Roadless Rule intact. Roadless areas are the last large, unfragmented ecosystems in the National Forest System. Once a road is built, the ecological function of that land changes permanently — soil compacts, water flow shifts, and the area becomes permanently open to logging, mining, and motorized traffic. National forests already contain over 370,000 miles of roads with a maintenance backlog in the billions. Roadless areas are the exception, not the rule, and that scarcity is why they matter. Wildfire rationale is unsupported. USDA claims the rule is a "barrier to wildfire risk reduction." But studies show wildfires were four times as likely in areas with roads than in roadless tracts, since roads increase human-caused ignitions. USDA should reconcile this rationale with its own data before finalizing anything. Endangered species and habitat loss: A recent study modeling this rescission found it would put roughly 400 species on an "extinction fast track," putting 7.4 million acres of critical habitat and nearly 1,800 miles of protected rivers at risk, threatening 88 species with designated critical habitat in roadless areas. The EIS should quantify these risks forest-by-forest. Habitat fragmentation: Grizzly bears, Canada lynx, and native salmon depend on large, connected landscapes, not isolated patches. Every mile of new road segments habitat, disrupts migration corridors, and opens new vectors for invasive species. Clean water: National forests are the headwaters of the country's major rivers and the largest source of municipal water, serving over 60 million people across 33 states. Roads are a major cause of water pollution in these watersheds; removing protections increases sediment and runoff into drinking-water sources. Climate and carbon storage: Roadless areas and old-growth forest on the Tongass alone store roughly 20% of all carbon held in the national forest system. Logging these stands releases stored carbon and removes a natural climate buffer. Logging impacts don't justify the tradeoff: The Roadless Rule reduced national timber harvests by less than 0.5%; a marginal economic gain for a permanent ecological loss. USDA should show, forest by forest, that timber value actually exceeds the recreation, water, and carbon value being forfeited. And if the value of the timber is down to exceed all other value, the first should remain protected and untouched. Mining waste: Removing protections opens roadless land to new mineral-access roads, tailings, acid drainage, and heavy-metal contamination. Contaminated watersheds are far more expensive to restore than to protect in the first place. Social and economic impacts: Outdoor recreation in these landscapes supports jobs and local economies that compound over generations if the land stays intact; extractive revenue is largely one-time. When the Roadless Rule was finalized in 2001, more than 1.6 million people commented, the vast majority in favor of protection — one of the most extensive public engagement efforts in federal land-management history. This rescission was originally given only 32 days for comment, later extended to October 6, with just a handful of public hearings nationwide. A decision affecting tens of millions of acres deserves a proportionate process. I urge the Forest Service to withdraw this proposal and retain the 2001 Roadless Rule in full. The evidence does not support the claim that removing roadless protections meaningfully reduces wildfire risk, while the costs to endangered species, clean water, climate stability, and public lands are well documented and severe. On a personal note, my fondest memories of my children growing up was our weekly camping trip into the Uinta National Forest every summer. Immersing ourselves in nature--the sound of bird song while the breeze rustled the branches, the smell of pine and freshly fallen rain, the cool crisp air first thing in the morning, looking up at a clear sky framed by towering trees while the kids explored the trails near the campsite--provided a release, a resetting that is so desperately needed in today's increasingly stressful world. There is so much more to life and legacy than money. Nature reminds us of that. And it must be protected.

I have spent a significant amount of time in the Uinta National Forest (40.6548, -110.9287, East of Salt Lake City. This wonderful land is deeply American and deeply wild. It also provides a substantial amount of habitat to Elk and Black Bear. I have had the freedom and pleasure to enjoy America's wilderness and by skiing, hiking, hunting, and birding in the Uinta National Forest. It has been a life changing experience and the development of these lands for resource extraction would be violation of our nation's values. One of America's first great authors Ralph Waldo Emerson wrote in his essay entitled Nature: "In the woods, too, a man casts off his years, as the snake his slough, and at what period soever of life is always a child. In the woods is perpetual youth. Within these plantations of God, a decorum and sanctity reign, a perennial festival is dressed, and the guest sees not how he should tire of them in a thousand years. In the woods, we return to reason and faith. There I feel that nothing can befall me in life,—no disgrace, no calamity (leaving me my eyes), which nature cannot repair. Standing on the bare ground,—my head bathed by the blithe air and uplifted into infinite space,—all mean egotism vanishes. I become a transparent eyeball; I am nothing; I see all; the currents of the Universal Being circulate through me; I am part or parcel of God. The name of the nearest friend sounds then foreign and accidental: to be brothers, to be acquaintances, master or servant, is then a trifle and a disturbance. I am the lover of uncontained and immortal beauty. In the wilderness, I find something more dear and connate than in streets or villages. In the tranquil landscape, and especially in the distant line of the horizon, man beholds somewhat as beautiful as his own nature". Please do not destroy "America the beautiful" and nature of man. It should be noted that while my exeperience is limited to the Uinta National Forest, all the current lands protected under the Roadless Rule should be preserved as such. Do not repeal this rule that preserves our national identity and our nature, both human and wild.

I strongly appose any changes to the current roadless rule. I am a hunter, backcountry skier, climber and conservationist. I recreate regularly in current roadless areas throughout utah, montana, and wyoming. In Utah I hunt and backcountry ski on the western side of the Uinta national forest near Kamas UT. Specifically near Hoyt peak, which is currently under protection of the current roadless rule. This area is special because it is true wilderness, leading to a rare and incredible backcountry experience in rugged country. Keeping this area free from development, and conserving current old growth trees, native plant species and water sources are vital for maintaining current ecological health of the greater utah ecosystem and helping prevent destructive wildfires. Along with maintaining a place to recreate that is still truly wild. Which is what makes the great forests of the united states unique. If the roadless rule is removed, you can count on me doing everything in my voting power to make sure a candidate in the future is put into office that will reinstate the rule and further enhance protections for public and protected landscapes.

To the Department of Agriculture: For someone who plans trips around what public land hasn't been developed, the 2001 Rule isn't background policy — it's a load-bearing part of how I think about where it's still worth going. I live and recreate in Utah. Bears ears, uinta mountains, so much area is protected now and I don't want oil companies drilling on this land, roads being built on this land. Money can't replace native species, native/historical dinosaur foot prints, rock art. Wild fires are made worse by roads. Native habitat, reintroduction of species like beavers and fish help restore the environment One visit made that connection concrete. I've camped in the uinta mountains for 20+ years. There are multitudes of alpine lakes that you can't drive to, you have to hike to. The lakes you can drive to have become so crowded, filling up with reservations a year in advance. The considerations above inform the position set out in the remainder of this comment. Regarding the 418040 in the Uinta National Forest, Utah: Under 40 CFR 1508.7, the ecological connection between 418040 and 418006 (11,714 acres, 23.5 miles apart) in Uinta National Forest constitutes a cumulative effects relationship. 14 species move between these IRAs, including imperiled species: Suckley's Cuckoo Bumble Bee (G2). Analyzing either area without reference to the other violates NEPA's cumulative impact mandate. The 23.5-mile corridor between 418040 and 418006 sustains gene flow for 14 species, including Suckley's Cuckoo Bumble Bee (G2). Road construction in either IRA severs this exchange, isolating populations that depend on movement between areas for genetic diversity and recolonization after local disturbance. Analyzing 418040 in isolation ignores the 14 species it shares with 418006 (11,714 acres, 23.5 miles away) in Uinta National Forest. Analyzing 418006 in isolation makes the same error in reverse. The DEIS must assess the connected system because fragmentation impacts are invisible at the single-area scale. "One of the most severe consequences of habitat loss due to road construction is the creation of isolated pockets of habitat that cannot support viable populations in the long term. Reductions in the range of species may decrease probability of their successful movement between habitat patches, which affects gene flow. Genetic theory suggests that the reduction of gene flow between subpopulations may lead to greater inbreeding and loss of genetic diversity within fragments, the raw material that allows populations to evolve in response to environmental changes." — Corlatti et al. 2009, Conservation Biology, 2009 “One of the most severe consequences of habitat loss due to road construction is the creation of isolated pockets of habitat that cannot support viable populations in the long term. Reductions in the range of species may decrease probability of their successful movement between habitat patches, which affects gene flow. Genetic theory suggests that the reduction of gene flow between subpopulations may lead to greater inbreeding and loss of genetic diversity within fragments, the raw material that allows populations to evolve in response to environmental changes. — Corlatti et al. 2009, Conservation Biology, 2009 (https://doi.org/10.1111/j.1523-1739.2008.01162.x)” “Researchers have concluded that wildlife corridors increase movement between habitat patches by approximately 50%, compared to patches that are not connected by corridors. Linking protected areas, such as national parks and wilderness areas, as well as other crucial habitats, ensures larger, cohesive landscapes of high biological integrity that allow for the migration, movement, and dispersal of wildlife and plants. — Center for Large Landscape Conservation (citing Gilbert-Norton et al. 2010), 2010 (https://doi.org/10.1111/j.1523-1739.2009.01405.x)” The proposed rescission lacks the factual and legal basis necessary to satisfy APA requirements; the Rule should remain in place. Respectfully, CommentID: RLC-20260901-Y7FPYW

Dear Secretary Rollins, I am writing as an angler and Utah resident to urge the Department to retain the 2001 Roadless Area Conservation Rule in its current form, and specifically to protect Inventoried Roadless Area 418024 in the Uinta National Forest. Why this matters to me This past summer, I went fishing in the Uintas with my best friend and his two brothers. We spent the day pulling up beautiful small high-mountain trout under a sunny sky with a cool breeze. I only started fly fishing this year, and it has become the main way I connect with my uncle, who is now confined to his home. He fished Utah's rivers throughout his youth and adulthood, and now that he can no longer get out there himself, I send him pictures and smoked fish to help him remember those days. That day was not an exceptional one — it's representative of what these waters offer, week after week, to people like me and my uncle. I fish these waters regularly, and I've started measuring stream temperature every time I go out, because I've noticed it rising. Trout stop biting for me once the water nears 70°F; a recent reading I took was already 65°F. As an angler, I'd note that the cold-water refugia the Roadless Rule helps protect are increasingly the difference between fisheries that survive a warm summer and fisheries that don't. If road construction and the sedimentation, canopy loss, and warming it brings are allowed into headwater tributaries like these, I don't think that margin will hold. The specific area at risk: IRA 418024, Uinta National Forest Road construction in this area's steep subalpine terrain requires cut slopes and fill material that erode into adjacent streams during snowmelt and summer storms. Building roads here would also remove the riparian spruce-fir canopy along the corridor, eliminating the shade that keeps these headwater tributaries cold enough to support trout in the first place — compounding exactly the warming trend I'm already measuring on the water. This concern is not just personal observation. A 2020 peer-reviewed synthesis in Conservation Science and Practice found that Inventoried Roadless Areas are among the most wild, undeveloped areas in the nation, that they reduce the isolation of protected areas and buffer them from external stressors, and that in many places they protect watersheds delivering drinking water to hundreds of thousands of people (Conservation Science and Practice, Wiley, 2020). The DEIS fails to analyze foreseeable impacts to species in this IRA Roads enable the equipment access, land conversion, and human activity that activate Threat 7.1 (Fire & Fire Suppression) under standard threat-classification frameworks. Without road infrastructure, the extractive and development pressures behind this threat category cannot reach Pinyon Jay (Gymnorhinus cyanocephalus, G3, state rank "Under Review") habitat within IRA 418024. The draft EIS does not appear to analyze this species-threat-area interaction. Failing to address how rescission-enabled road access would expose Pinyon Jay habitat in 418024 to fire-and-fire-suppression-related threats leaves the administrative record incomplete on a foreseeable and reasonably identifiable impact. Under NEPA, an EIS must take a "hard look" at reasonably foreseeable environmental consequences; an analysis that omits this interaction is arbitrary and should be corrected before any final rule is adopted. Conclusion I urge the Department to retain the 2001 Roadless Rule in its current form for IRA 418024 and comparable headwater areas, and to require the final EIS to directly analyze the sedimentation and stream-temperature impacts of road construction on cold-water fisheries, as well as the species-threat-area interactions — including Pinyon Jay and Threat 7.1 — that the current draft omits. These are working trout streams that support real fisheries and real people. I fish them. My uncle fished them for decades before me. Please help keep them intact. For the record: the Rule should be kept in place. With kind regards, Amy Ollerton, Provo, UT CommentID: RLC-20260823-TPIETI