Read the comments.

Repealing the roadless rule would cause serious erosion damage to forests that are protected under it, and would open up inroads for logging, mining, and oil and gas companies to drain the protected forests of their valuable resources. The White House claims that rolling back the roadless rule is for the creation of roads to allow emergency and fire vehicles into the wilderness, but 95% of forest fires start within half a mile of a road. I spend almost every weekend running in White River NF and would be devastated to see this beautiful forest be cut up by roads and then logged. Please do not repeal this rule!!

To the U.S. Forest Service: I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user and advocate for our nation's public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. I frequently visit the the Linville Gorge, Wilson Creek, and Harper Creek areas of Pisgah National Forest near my home in Boone, North Carolina. I also travel frequently to enjoy our public lands across the nation, and for many years was lucky enough to call the White River National Forest of Colorado home. There aren't words to describe how deeply personal protecting these unfragmented landscapes is to me because not only do I depend on these watersheds for clean drinking water (I have a well, my parents have a spring fed tap), I also frequently explore the backcountry trails with my two dogs, and our community depends on the tourism that comes from the beauty of this ancient mountain region. I also put immeasurable value in our pristine wildlife habitats, that provide our unique biodiversity and enjoy the bears, fox, owls, deer, coyote, woodpeckers, hummingbirds, hellbenders, and countless other priceless species that I call neighbors. I BEG the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to listen to your citizens and abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Please place the natural value of our wild and beautiful nation above the material value in order to provide not only this generation but your children's generation, the opportunity to learn & grow from these unspoiled lands. We are all counting on you to see reason. Sincerely, McClure Jackson-Cathcart, RVT Boone, North Carolina

Continued: 4. Fire is a part of the ecosystem. To the extent that the rationale is reducing fire, the rationale is wrong, as other commenters have pointed out and as the rationale points out, that more roads lead to more fire activity. But also the entire proposal is misplaced — because the most effective way to address fires of increasing intensity is to address climate change. That is the real national priority that needs to be addressed that the government is completely failing to address. Roads in forests are not a recognized wild-land fire management policy, as other commenters have pointed out. *** Put simply, the repeal of the Roadless Rule is a step backwards in public lands management. It effectively takes public lands out of the hands of the people they are set aside for — the American public — and hands them to special interests who are willing to pay for them. This is not the mandate that the USFS has been given by Congress. The mandate is the manage these lands for multiple uses. Creating new roads in forests prioritizes only one use, timber harvesting, over all others. *** My experience in this comment is drawn from recreating at the following USFS properties: Little Missouri National Grassland; Buffalo Gap National Grassland; BigHorn National Forest; Chequamegon-Nicolet National Forest; Hiawatha National Forest; Ottawa National Forest; Huron-Manistee National Forest; Superior National Forest; Chippewa National Forest; Shoshone National Forest; Custer-Gallatin National Forest; Flathead National Forest; Bridger-Teton National Forest; Caribou-Targhee National Forest; Gifford Pinchot National Forest; Olympic National Forest; Okanogan-Wenatchee National Forest; Mount Baker-Snoqualmie National Forest; Colville National Forest; Medicine Bow-Routt National Forest; Arapaho National Forest; White River National Forest; Black Hills National Forest; Thunder Basin National Grassland; Unit-Wasatch-Cache National Forest; Sierra National Forest; Stanislaus National Forest; Lincoln National Forest; and Shawnee National Forest. My major takeaway from all these experiences is that these Forests already have more roads than most people could explore in a lifetime. There is quite simply no practical or logistical need, from a recreational perspective, for more under the rationales that the USFS has proposed in this rule change.

I am opposed to changes to the roadless rule. It is a significant measure that has been effective in preserving and managing natural resources, hiking, fishing and hunting opportunities that the public enjoys and support. I have been a visitor to national forest lands in Colorado (Uncompahgre NF, Rio Grande NF, White River NF), Utah (Dixie NF, Fishlake NF), California (Sierra NF, San Gabriel NF, others), Arizona (Coconino NF, Kaibab NF), others. I support the roadless rule and I don’t support eliminating it. Yes, the President’s donors may be trying to benefit from removing the rule, but a majority of the public supports preserving it. Utah politicians like Lee may claim no one supports measures like the roadless rule, but he is undoubtedly pandering to outside interests.

My name is Joan Harvey. I live in the mountains above Boulder, Colorado. I grew up near the White River National Forest and spent my childhood hiking in many of the National Forests in Colorado. I know that Colorado is exempt from this repeal. But rescinding the 2001 Roadless Area Conservation Rule can destroy other forests equally worth saving. And it can make wildfires worse by increasing human access and industrial activity which are the leading drivers of forest fire ignitions. Up to 88% of wildfires in the US are caused by human activity. Research indicates that wildfire ignitions is significantly higher within short distances of roads compared to remote, roadless areas. Clearing trees and vegetation for roads opens up the forest canopy allowing sunlight and wind to dry out the soils, making the landscape more susceptible to rapid burning. And opening millions of acres to development stretches the already limited Forest Service budget. While I live in Colorado I often spend time in forests in other states, such as the Manti-LaSal National Forest in Utah where there are already many existing roads, and the last big fire was started at a campsite, not in a roadless area. Thank you.

To the Forest Service: I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR part 294, subpart B). I haven been an avid hike for almost 20 years, hiking several times a week (or more). This includes national parks and national forests including the following: • Angeles National Forest • Arapaho National Forest • Carson National Forest • Cleveland National Forest • Inyo National Forest • Lassen National Forest • Pike National Forest • Rio Grande National Forest • Roosevelt National Forest • Routt National Forest • San Bernardino National Forest • White River National Forest Hiking is important to both my physical and mental health and has played an important role in my volunteer work to help veterans reintegrate following their service and find community. Taking them on hikes has been a powerful way to bolster their health and wellness. The 2001 Rule protects roughly 58.5 million acres of inventoried roadless areas by generally prohibiting road construction, road reconstruction, and timber harvesting, with limited exceptions. Rescinding it removes that protection nationwide. The notice states that the rescission does not itself mandate timber cutting or road building. But it removes the rule that currently prevents them, and the agency should be candid that this makes road construction and logging in these areas possible where they are now generally prohibited. For hikers, the value of these areas is that they are undeveloped. A trail through a roadless area offers quiet, solitude, and a sense of remoteness that cannot be rebuilt once a road is cut through. Opening the door to new roads and logging puts those experiences at risk, and the loss would be permanent in a way that is very hard to undo. The Department's stated reasons for the proposal are to reduce regulatory burden and to return decisions to local Forest Service officials. I ask the agency to address the following in the final rule and EIS: How will recreation be weighed? If decisions move to the local level, what required standard will ensure that the value of undeveloped backcountry for hiking and other dispersed recreation is considered, rather than left to discretion project by project? What is the burden being relieved? Please identify the specific, documented costs of the 2001 Rule, and show that they outweigh the benefits of keeping a consistent nationwide protection. Why rescind rather than amend? If there are specific problems with the rule, why does the Department propose eliminating it entirely instead of a narrower fix? How will the public be involved? Under the proposal, how would hikers and other recreation users learn of and comment on future decisions affecting individual roadless areas? I also ask that the Department give the public adequate time to review a proposal of this size. The rescission was issued alongside a draft environmental impact statement and a cost-benefit analysis, with an original 30-day comment period. I urge the Department to withdraw the proposed rescission and keep the 2001 Roadless Area Conservation Rule in place. Sincerely, Laura W. Fort Collins, CO

Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule – Docket No. FS-2025-0001 To the U.S. Forest Service and the U.S. Department of Agriculture: I am writing to express my strong opposition to repealing the Roadless Rule. I am an undergraduate student studying Environmental Science. As a resident in Colorado, I have grown up with the woods as my backyard. I have seen firsthand what wonderful creatures and ecosystems can flourish in protected areas. As a kid, I was able to hike, fish, and connect with my family in the outdoors in protected wilderness areas such as White River National Forest. Opening these areas up to road development, logging, and housing is detrimental to these ecosystems. This will put watersheds at risk for pollutants, further habitat fragmentation, put species in danger, and make the already wildfire-prone forest more susceptible to wildfires. I urge the Forest Service to select Alternative 1 (No Action) and maintain full, nationwide protections for all designated inventoried roadless areas. Sincerely, Karis Fischer Littleton, CO, 80129

Dear Secretary Rollins, I oppose the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule. As an Avon, Colorado resident, I am surrounded by the White River National Forest. I regularly use these lands for hiking, camping, birdwatching, and wildlife viewing. This forest and other forest areas like them, provide critical habitat for wildlife. Rocky Mountain elk and bighorn sheep (whose populations are declining), the Canada lynx and greenback cutthroat trout (federally listed as "threatened"), in addition to bald and golden eagles (listed as federally "protected") will be negatively impacted by changes to their environment. And, those of us who appreciate them and their native habitat will also be negatively impacted. Altering the Roadless Rule opens acres of the White River National Forest—and millions more acres of national forest across the country—to road construction and commercial activities, with irreversible impacts on wildlife, ecosystems, and people. For this reason, I oppose fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS. All areas protected by the 2001 Roadless Area Conservation Rule should remain protected as they are today. I support Alternative 1, the “No Action” Alternative. Sincerely, Charlotte Shollenberger

I am writing to express my strong opposition to the Forest Service’s proposal to rescind the Roadless Rule. I am an avid outdoor recreationist who regularly visits roadless areas in America's national forests. For the last 55 years I have camped, hiked and backpacked in most of Colorado's National Forests, doing many trips each year in the White River National Forest, Rio Grande National Forest, Arapahoe National Forest, Roosevelt National Forest, Pike National Forest, San Isabel, and San Juan National Forest. These are some of the main ones. I have also hiked, camped and backpacked in Wyoming's national forests such as the Teton National Forest, Bridger National Forest and Bighorn National Forest. I have also hiked and backpacked in much of southeast Utah. Most of my backpack trips are from 4 to 12 days covering 40 to 100 miles per trip. I have enjoyed all the beauty the National Forests have to offer such as the wildlife, fishing and clean water that is presently there. This is where I rejuvenate, refocus and clear my head. Logging and road building would spoil these untouched, pristine National Forests and they must remain roadless. The roadless National Forests help provide clean drinking water to downstream communities, are home to cold, crystal-clear trout fishing streams, boast world-class hiking and mountain biking trails, support local businesses, provide habitat for at-risk animal species, and offer unmatched experiences for visitors looking to get away from the noise and commotion of roads. I believe that road building for logging in the National Forests would do long-lasting damage to these incredible public lands, to the wildlife, water and to communities that benefit from them. The financial gain would not justify the damage. As far as management goes what could be less complicated than managing all the national forests through one simple and clear mandate of the current roadless rural. Why fragment the management which would occur for each individual National Forest. Think of all the increased litigation that could result when each National Forest has its own management rules and is litigated separately. I strongly urge you to keep the Roadless Rule in place as-is, so that future generations of hikers, anglers, mountain bikers, hunters, climbers, birders, and paddlers can enjoy these amazing roadless places. Thank you for considering my thoughts Tom Lohaus Colorado

As an outdoor recreator and outdoor guide, I have made countless cherished memories and spent much of my life in areas protected by the Roadless rules. Specifically, areas of Olympic National Forest, White River National Forest, and the Goat Rocks Wilderness have held a big enough place in my heart as to warrant calling them my places of worship. These natural areas provide a unique opportunity to experience nature and the natural world that can not be sustained with new growth and logging operations. The lack of access and development are what make these unique areas so valuable and beneficial, not the callous and shortsighted logging and developing of the natural world. Rescission of this rule undoubtedly and irrefutably will lead to ecological harm that we as Americans will have to face, along with the thousands of species and complex ecosystems that call these places home. Clean and safe drinking water, clean and safe air to breathe, a healthy ecosystem that numerous studies show is a positive benefit to humans to simply experience, all rely on the blocking of this rescission. Time and again, economic forecasts and models have shown that the short term economic gain from opening these areas to industrial interests is dwarfed by the benefits of keeping them as they are. The profits from tourism to natural areas alone far exceeds the amount generated by private industry in these areas and to attempt to claim otherwise is a clear and blatant lie perpetuated by capital interests. It is time to end this inane conversation and expand, not degrade, our protected public lands. In summation, I, along with a clear majority of the American public, unequivocally oppose the rescission of the Roadless Rule(36 CFR Part 294, Subpart B (66 FR 3244))

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Elk Mountains are where I spend my summers. I run day trips across some of Colorado's most technical 14ers carrying nothing but a day pack and some running shoes. I also photograph action sports, including skiing, climbing, biking and running, and so much of that work takes place in roadless areas. What I am fighting for in this comment is not abstract. I live very near East Creek B, a 7,178-acre roadless area in the White River National Forest, and I love exploring the old trails that run all around the ridges and valleys there. Elk, deer and bear can be found there all year long, and it should be protected at all costs. I am asking this agency to withdraw the proposed rescission of the 2001 Roadless Area Conservation Rule. Grizzly Creek, 6,612 acres also in the White River, provides a little respite from the noise and bustle of I-70 passing through Glenwood Canyon. The trail takes you back into the hills, where you can loop over a remote pass and connect back to the bottom of the canyon. That area was hit by a fire several years ago and is still in the process of recovery. Any road construction in this area would cause permanent and irreversible damage to an ecosystem just bouncing back from catastrophe. The agency's own record agrees with the logic of that concern: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the agency's justification for rescission includes better fuels management, I ask that it explain why it departs from these findings and reconcile the proposal with the ignition data in DEIS Table 21, which its own record shows reports far higher fire density on roaded land than inside the affected roadless areas. The wildlife I see in East Creek B depends on these protections. The agency's own DEIS record, citing Rowland, Unsworth, and Cole, found that elk avoid areas near roads and select unroaded habitat for summer cover and forage, and that elk survival rates rose during a road closure and fell again when the gates were removed. For deer, the agency's own analysis cites research finding that roads built for resource extraction may have altered mule deer migration routes and increased their movement speed, disrupting the unroaded security these animals depend on. On bear, the DEIS draws on the federal grizzly recovery plan and states that the increased contact and conflict that come with open roads can ultimately end in grizzly mortality, and that shooting, habituation and food reward all increase with the use of even secondary unpaved roads. The agency should address in this proceeding what specific countervailing wildlife finding supports removing protections that its own science says are keeping these animals alive. The White River National Forest is the most visited national forest in Colorado and part of the headwaters of the Colorado River, which supplies water to 40 million people in seven states and Mexico. Across the Rocky Mountain region, 325 municipal water intakes sit in watersheds containing affected roadless areas. Roads increase sedimentation and degrade those watersheds. I want the agency to explain how the rescission accounts for those downstream consequences. The economics of this proposal do not hold up. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own cost-benefit analysis projects timber revenue of $5.2 to $11.4 million a year to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. Finally, on authority: the agency suggests the 2001 rule exceeded its statutory power. A federal court of appeals considered that exact argument and held otherwise. The Tenth Circuit's ruling was unambiguous: "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 should state plainly what legal basis it now believes supports a contrary position. The places I named here are real. The trails exist. The animals are there. The rescission should not proceed. Sincerely, Sky Couvreux Redstone, CO

To Whom It May Concern, My name is Adam Love. I am a resident in Centennial, CO 80121, and I strongly oppose the full or partial removal of the Roadless Area Conservation Rule. The Roadless Rule protects conservation areas in the White River National Forest, Arapahoe National Forest, and other areas around the state where I recreate. Furthermore, the recision of the Roadless Rule risks jeopordizing the water quality for millions of people, threatening the habitat of threatened and endangered species like gray wolves, grizzlies, and wolverines, negatively impacting the ability for the forests to sequester carbon (especially with the potential logging of old trees), and dramatically increasing the risk of wildfire in these areas. Roads create gateways for extractive industries. I am a father, and I am worried and frankly outraged that repealing this rule will not only harm the myriad plant and animal species that call these wilderness areas home, but will also throw away future generation's access to pristine nature. Studies have repeatedly shown that wildfire risk increases with the presence of roads. What has the agency done to adequately address these risks with the proposed recision of the Roadless Rule? What are the ecological impacts of fragmenting the wildlife corridors that will be impacted because of these changes? Some of my favorite areas to explore are protected under the current Roadless Rule, but recision of this key peace of conservation legislation opens those protected areas to extractive industries. Wildfires are 4x more likely to start near roads, and many of the places protected are the foundation of key watersheds that cities like Centennial and Denver rely on for clean drinking water. Again, I strongly oppose removal of the Roadless Rule, either in full or in part, and instead ask for the Forest Service to adopt a 'no action alternative' to keep the Roadless Rule fully intact. Thank you for addressing my concerns and those of countless other citizens who are looking to you to be faithful stewards of these great lands. Respectfully, Adam Love

Dear Forest Service Officials, As a resident of Colorado who frequently hikes and camps on public land, I am writing to express deep concern regarding the proposed full rescission of the 2001 Roadless Area Conservation Rule. While I recognize that Colorado’s roadless areas currently remain under state-specific governance, the removal of this federal protection across millions of acres nationwide threatens the overarching integrity of America’s national forest system. Intact backcountry areas—such as those adjacent to the wilderness and high-use recreation zones in the White River National Forest—safeguard vital headwaters and critical big game habitats. Elk, Bear and Moose do not adhere to state boundaries! Furthermore, the justification that road construction aids in wildfire mitigation is contradicted by recent Forest Service as many more man made fires start near roads. I urge the agency to abandon the complete rescission of the 2001 Roadless Rule and preserve strong national conservation baselines for our public forest heritage.

To the U.S. Forest Service: Watching federal rules come and go for a quarter century, I'd say the 2001 Rule is one of the few I'd want my kids to see still on the books in twenty years. As a guide, that's a long-horizon judgment. Truly natural, wild, untouched spaces are extremely valuable to me. I work and recreate in them and operate my life around healthy wilderness. It is imperative that these conditions exist for future generations. The area protected by the rule is substantial and provides extensive habitat to millions of organisms. The human hand should be left out of these areas. Biodiversity is essential to the health of these ecosystems and the planet. We need to do everything in our power to promote biodiversity in wild areas. Regarding the Red Table in the White River NF, Colorado: The threat mechanism classified as 7.2 - Dams & water management/use (IUCN-CMP 7.2) is actively degrading habitat for Bonytail (Gila elegans, G1) in the Red Table Inventoried Roadless Area, White River NF, at Extreme or 71-100% pop. decline severity across Pervasive (71-100%) scope. For Bonytail in Red Table, the connection between road construction and 7.2 - Dams & water management/use is direct: roads deliver the disturbance vectors — sediment, access, fragmentation — that NatureServe identifies as driving Extreme or 71-100% pop. decline severity impacts on this population. The DEIS must provide site-specific analysis of 7.2 - Dams & water management/use impacts to Bonytail (Gila elegans) in the Red Table IRA — not a programmatic discussion of roadless areas generally but a particularized assessment of this species in this place. "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." — Fire Ecology (Springer Nature), 2026 The Forest Service is urged to allow the 2001 Rule's protections to continue without interruption. Respectfully submitted, CommentID: RLC-20260921-WARR1O

I believe I live the American Dream. I graduated from college (Temple University) in the spring of 2007. I visited Breckenridge, Colorado a few times during my last couple of years in college. Like so many, I was drawn by the mountains and the ample recreational opportunities they provide. With eyes wide open and my mind blown by the beauty, I realized people are able to make a living in a mountain town like Breckenridge. So as soon as I graduated, I moved halfway across the country from my childhood home to Breckenridge. Upon arrival, I opened a business. Now, and for the past 19 years, I’ve made my life and my business work within the borders of the White River National Forest. Without compare, my favorite places within the forest are the roadless areas. They provide the untouched snow I ski upon. They are home to the singletrack trails I mountain bike on. I frequent the roadless areas in the forest to be closer to nature. To understand the natural world better. To hear its quiet. I honestly could not live without it. Neither can most species. Beyond the importance of protecting roadless areas to maintain needed habitat for wildlife and diverse ecology, people that live in mountain communities like me rely on the forest to provide the recreational opportunities that drive our economy. Towns like Breckenridge make a lot of money simply because they are beautiful places with a vastness of untouched wilderness for people to explore. We do not need roads to explore. As a matter of fact, their presence ruins the exploration more often than not. I pray and I trust that our country will do the right thing and keep the roadless rule in place. Sincerely, Brian Raitman

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Thru-hiking the entire Continental Divide Trail changed my life. Over 100+ days on trail, I moved through some of the most intact wild country left in this nation. Repealing the 2001 Roadless Area Conservation Rule affects roughly 376 miles of the CDT, and that is unacceptable. The lands and trails were protected for a reason. They are beautiful for our country, and I am asking this agency to defend that protection, not dismantle it. I am also learning to hunt with my partner, who has hunted his entire life. Hunting means recreating on our public land, spending quality time together, and putting food on our family's table. The roadless areas of the White River National Forest, including Grizzly Creek at 6,612 acres, Deep Creek at 9,876 acres, Sweetwater A at 11,931 acres, and the others I have identified in this docket, are the kind of country those pursuits depend on. I also bike all over Colorado, including permitted areas within public lands. Public lands are an amazing way to calm the mind, exercise our bodies, and refresh our minds for the upcoming work week. Opening these areas to roads ends that. The White River is the most visited national forest in Colorado and holds 90 inventoried roadless areas totaling 639,604 acres. It is headwaters to the Colorado River, which supplies water to 40 million people in seven states and Mexico. I want the agency to explain clearly what this proposal does to that water supply and to those 90 areas. The agency justifies rescission partly on wildfire and fuels management grounds. Its own prior 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 does not reconcile that finding with its current reasoning. 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 its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission does not hold up either. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. That range cannot establish a net benefit. The road system the agency already maintains carries a $6.9 billion maintenance backlog. The agency must reconcile this proposal with those numbers. The proposal argues that state-specific approaches can replace a national rule. The agency attempted exactly that before. The Ninth Circuit identified serious deficiencies in that approach, including the finding that local decision-making can incrementally reduce nationally significant roadless values. Rather than reproduce the language the agency used to describe its own dissatisfaction with the 2001 rule's approach, I raise the substance directly: the agency has not explained how this proposal avoids the same constitutional and procedural deficiencies the courts identified the last time it tried to substitute state-by-state management for a uniform national standard. I ask that the agency answer that question in this record. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. The Tenth Circuit addressed that directly: "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 held the 2001 rule was within authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency owes this record a clear explanation of what legal basis supports a contrary position today. Colorado's 326 inventoried roadless areas total 4,407,277 acres. Across the Rocky Mountain region, 325 municipal water intakes sit in watersheds containing affected roadless areas. I understand that Colorado's areas are governed by the 2012 Colorado Roadless Rule, which this proposal retains. What the agency has not answered plainly is what, if anything, changes in the management of those areas as a practical matter. That question deserves a direct answer here. Sincerely, Meghan Hill Avon, Colorado

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The fairy slipper orchids come up in the early summer in the White River National Forest. By midsummer my family is tracking paintbrushes and elephantella, and by late summer we are working to find all six local species of gentian on a single hike. I hike on and off trail there because the roadless landscape represents water, wildlife, connection with nature, and generational wisdom. I am writing in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The White River holds 90 inventoried roadless areas totaling 639,604 acres. It is the headwaters of the Colorado River, which supplies water to 40 million people in seven states and Mexico, and it is the most visited national forest in Colorado. Colorado roadless areas are currently governed by the 2012 Colorado Roadless Rule, which the proposal states it would retain. What the agency has not explained is what, if anything, changes in their management as a consequence of this rescission. I ask the agency to answer that question directly and specifically on the record. On wildfire, the agency's stated justification for rescission includes fuels and fire management, but the agency's own prior findings cut the other way. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." DEIS Table 21 confirms far higher fire density on roaded land than inside the affected roadless areas. The proposal does not reconcile itself with those findings. I ask that the agency explain why it is departing from them and how it accounts for the ignition data in its own analysis. On economics, the scale of what is at stake is modest by the agency's own numbers: "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." Yet the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. The Forest Service is already carrying a $6.9 billion road maintenance backlog. The agency must explain on the record how expanding a road system burdened by that backlog is justified when its own analysis cannot establish a net benefit. The regulatory flexibility analysis certifies no significant impact on small entities, but the DEIS identifies outfitters, guides, and tour operators as affected, and the Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The certification reaches its conclusion by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas, and it concedes that some of those firms may lose those receipts. The certification should be withdrawn and the analysis should assess the businesses actually operating in the 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 family has built our seasonal routine around the wildflowers of these roadless areas. The gentians, the orchids, the paintbrushes exist in the condition they do because roads have not come in behind them. That is a reliance interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. My children deserve to inherit roadless places and a democracy in which huge changes to public land do not happen without public input. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the Roadless Rule, but has held exactly none to undo it. That is wrong, and the agency should say plainly how it answers for it. Sincerely, Denali Barron Aspen, Colorado

The Gunnison and Colorado watersheds are where I spend the time that matters most to me. I hike and backpack in the Gunnison National Forest, the Grand Mesa National Forest, the White River National Forest, the West Elk Wilderness, the Raggeds Wilderness, the Mount Sneffels Wilderness, and other wild places across Colorado. I paddle those rivers and their tributaries, and I have seen firsthand what roads and expanded human access do to a river's health. I have also stood at the pristine headwaters of the Gunnison River, in areas protected by the Roadless Rule, and understood clearly that those waters would be worse off if these protections were lifted. That is why I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The inventoried roadless areas I care about most directly include Roubideau (21,575 acres), Kelso Point (34,353 acres), Cimarron (15,638 acres), Tabeguache (11,504 acres), Beaver Creek (1,877 acres), and Badly Peak (1,948 acres), all within the Grand Mesa-Uncompahgre-Gunnison National Forest. The White River National Forest, where I also spend time, holds 90 inventoried roadless areas totaling 639,604 acres and contains the headwaters of the Colorado River, which supplies water to 40 million people in seven states and Mexico. I understand that Colorado roadless areas are currently governed by the 2012 Colorado Roadless Rule, which this proposal retains. I ask the agency to explain specifically what changes, if anything, in the management of Colorado roadless areas as a result of this rescission, and to answer that question on the record. The proposal uses wildfire and fuels management as partial justification for opening roadless areas to road construction. The agency's own record says otherwise. Its prior findings state: "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." I hike and paddle in the elk habitat of the Gunnison country, where elk survival is known to rise during road closures and fall when gates reopen, because elk select unroaded land for cover and forage. Roads are not a neutral instrument in these landscapes. I ask that the agency explain how the proposal departs from its own prior ignition findings and reconcile the rescission with the fire density data in DEIS Table 21, which shows far higher fire incidence on roaded land than inside the affected roadless areas. The small-business certification accompanying this proposal is contradicted by the analysis sitting beside it. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." That certification was reached by spreading an annual expenditure loss across every small firm in the sector nationally, not by assessing the outfitters and guides who actually hold permits in the affected areas. The agency concedes some firms may lose those receipts. The agency must withdraw the certification and conduct an honest assessment of the small entities actually operating under permits in these areas, not the national average firm. Finally, the proposal itself 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. This comment is one such interest. My paddling, my hiking, and the water I drink from the Gunnison and Colorado watersheds have all been shaped by the expectation that these protections would hold. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Bekah Scalero Paonia, CO

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 B"H The country I am writing about includes the White River National Forest. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I've recreated in the White River National Forest and surrounding areas for more than 20 years. After nearby roadwork, I've seen more sediment in the water, increased bank erosion, and muddier, less stable habitat. To name a few I hike, camp, fish, rock climb, forage, ski, and ice skate throughout this country. I also seek its quiet to get away from everyday noise, talk/pray to G-d, & think about my choices and meaning. Building more roads into undeveloped country makes little sense when the agency is already billions behind on maintaining existing roads. New roads also fragment habitat, increase erosion and stream sediment, spread invasives, and add disturbance to intact places. Millions drink water originating in these relatively unimpaired watersheds. My future children should not inherit fewer wild places than I did.I want them to know country without roads, engines, or constant development, and to have the same chance to find perspective and meaning there. The 2026 fire season reinforced this: some days the mountains vanished in smoke, the air smelled of it all day, the sun became red, and poor air quality made me think twice before going outside. I submitted comments during the previous rescission process and raised specific concerns. The agency owes the public comparable effort in return. You don't have to agree with me, but you should engage with what I actually said. I raise the following issues for the record and ask that the agency respond to each: Issue 1: Road sediment is quantified and then set aside I paddle and fish water that starts in this country; clean, free-running rivers are why I go. The DEIS says skid roads, trails, log landings, and similar timber-sale disturbances are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." Yet no projection of sediment delivery follows. I ask the agency to quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. Issue 2: Twenty-four million people's drinking water is asserted away I am downstream of decisions made in these forests. About 24 million people use water originating within potentially affected roadless areas through more than 7000 municipal intakes, and less than 12 percent of these watersheds are currently impaired. The DEIS says forest plans address public drinking-water sources without identifying one enforceable provision. I ask the agency to identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. Issue 3: Unmaintained roads damage water, by the agency's own admission I live with whatever a watershed sheds. A road nobody can afford to maintain eventually fails into the river. The agency states: "Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance." Yet the proposal would add road mileage despite a maintenance shortfall the agency identifies as a cause of water-quality damage. I ask the agency to reconcile those positions. Issue 4: Fragmentation is quantified and not applied Good fishing depends on intact, connected watersheds. The DEIS cites a finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, yet provides no projection across the 40.1 million affected acres. I ask the agency to apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. Issue 5: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and guides help people like me access them. The proposed rule certifies no significant impact on small entities while the DEIS identifies outfitters, guides, and touroperators as affected and its Cost Benefit Analysis estimates at least $6.1 million/year in lost recreation benefit. The regulatory flexibility analysis reaches its no-impact conclusion by spreading a $9 million annual expenditure loss across every small firm in the sector nationally instead of assessing permit-holding outfitters and guides in affected areas, while conceding some firms may lose receipts. I ask the agency to withdraw the certification and assess the small entities actually operating in potentially affected roadless areas. I request that the agency respond in the record to each issue raised here and analyze in the DEIS an alternative retaining the 2001 rule's protections. Where this proposal reaches factual conclusions that differ from the agency's prior findings quoted here, I ask the agency to acknowledge the change in position and provide a reasoned explanation on the record.

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain the rule. National forests are an important part of my life. I spend considerable time hiking, skiing, camping, and exploring the Coronado and Coconino National Forests in Arizona and the White River National Forest in Colorado. My opposition to rescission is based particularly on four concerns: watersheds, wildfire, costs, and the availability of targeted alternatives. Watersheds. Protecting western watersheds should be a primary reason to retain the Roadless Rule. Roadless forests capture snow and rainfall, filter water, stabilize soils, and limit erosion and sedimentation. These functions are especially important in the arid West. The forested mountains of the Coronado and Coconino rise above much drier landscapes, while high-elevation forests in Colorado accumulate snow that supplies communities, agriculture, rivers, and ecosystems far downstream. Road construction and associated logging can increase erosion and sedimentation and fragment intact watersheds. At a time of persistent drought, higher temperatures, and increasing demands on limited western water supplies, we should be protecting these natural systems, not weakening them. The Forest Service should fully account for the value of the watershed services provided by roadless areas and the long-term costs of degrading them. Wildfire. I agree that reducing wildfire risk and restoring forest health are urgent priorities, but the Forest Service should demonstrate that rescinding the Roadless Rule would actually accomplish those goals. The existing rule already allows road construction in some circumstances to address fire risk and allows thinning of young trees to reduce hazardous fuels. Roads can also increase human access and opportunities for human-caused ignitions; research cited by the Grand Canyon Trust finds fires are substantially more likely to start in areas with roads. Limited wildfire-management resources should be directed to treatments demonstrated to reduce risks to communities, homes, and infrastructure. The Forest Service should show that opening millions of roadless acres to additional roads and logging would reduce wildfire risk more effectively than strategically located treatments, particularly near the wildland-urban interface. Costs. The Forest Service already manages more than 371,000 miles of roads and faces nearly $5 billion in deferred transportation maintenance. Adding roads to a system the agency already struggles to maintain is fiscally irresponsible. New roads create continuing costs for drainage, erosion control, repairs, and eventual decommissioning. The Forest Service should account for these full life-cycle costs and explain why facilitating additional road construction makes sense when existing roads already have such a substantial maintenance backlog. Targeted alternatives. The Forest Service has not demonstrated that management problems in particular locations require rescinding protections across roughly 45 million acres nationwide. If specific roadless areas present circumstances in which existing exceptions prevent necessary wildfire mitigation, restoration, or other essential management, those circumstances should be identified and addressed specifically. If the problem is place-specific, the solution should be place-specific. The Forest Service should seriously evaluate retaining the Roadless Rule while modifying or expanding narrowly defined exceptions where a legitimate management need can be demonstrated. It should explain why targeted changes are inadequate before choosing nationwide rescission. The Roadless Rule has protected these lands for 25 years while allowing exceptions for legitimate management needs. The Coronado, Coconino, and White River National Forests are places I return to year after year, but my opposition goes beyond personal attachment. Protecting intact watersheds, directing wildfire resources where they will be most effective, avoiding unnecessary infrastructure costs, and choosing targeted solutions over nationwide rescission are sound principles of public-land management. Please retain the 2001 Roadless Area Conservation Rule. Sincerely, Kristin L. Gunckel Tucson, AZ