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Dear Special Areas: Roadless Area Conservation, se01nsnn se01nsnn , I urge you to keep the Roadless Rule in place (choose the No Action alternative.) As Americans, it is our patriotic and more importantly moral duty to safeguard these sacred lands from exploitation by the privileged few who would rip up every last tree, pollute every body of water and who otherwise seek to endanger and destroy every living creature (including human life) and every precious ecosystem that the Earth has given us. It is our god-ordained duty to steadfastly stand in the way of the regressive spirit of those who seek to destroy and exploit the natural beauty and life of this great nation, only for the purpose of gross profit and greed, at the expense of current and future generations of Americans and all people of this planet Earth. Keep the Roadless Rule! Thank you. Eric Heming 2071 S Fox St Denver, CO 80223 Sincerely, Eric Heming

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Born and raised in Alaska, the Tongass National Forest is near and dear to my heart, and I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). The Tongass is the largest intact temperate rainforest left on Earth. It holds 110 inventoried roadless areas totaling 9,339,575 acres, over 12,930 miles of salmon-producing streams, and roughly 44 percent of all the carbon stored by US national forests. Executive Order 14153 directs the agency to expressly exclude the Tongass from the 2001 Roadless Rule, and the Federal Register rescission notice says so in writing. Under both action alternatives, the Tongass keeps zero acres of roadless protection. That is not a reform. That is a permanent transformation of a place that cannot be rebuilt once it is gone. I work for our National Scenic Trails, which includes the Continental Divide Trail. Thru-hikers, hunters, and day users depend on the landscapes and watersheds that the Roadless Rule currently protects. The potential impact of logging would be detrimental to drinking water for many Americans in states where protections do not currently match the Roadless Rule. Having lived near fast-spreading wildfires, I know the impact is hard on communities where homes and livelihoods are lost. National forests that are easily accessible by the public should be managed for forest health in ways that reduce wildfire risk and support the communities around them. 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." Sincerely, Sarah Wilson Lakewood, CO 80215

Dear Secretary Rollins, I strongly oppose the USDA’s proposal to eliminate or weaken the Roadless Rule. As someone who was born and raised in Colorado, I grew up camping, hiking, fishing, and hunting. Through my life experiences with these activities, I have come to value them so deeply that any legislation or policy that puts those things at risk is of immediate concern to me. I believe that all peoples should be able to enjoy these activities with ease and our government should uphold that. Legislation that destabilizes and part of the 2001 Roadless Rule would devastate public lands, waste taxpayer resources, and undermine the water, wildlife habitat, and recreation opportunities on which millions of Americans depend. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean drinking water, provide refuge for vulnerable species, and serve as critical carbon sinks critical to mitigating the worsening impacts of climate change. People hike, forage, bike, fish, camp, ski, climb, and find solace in these remote places. Roads spread invasive species, fragment wildlife habitat, and erode the very ecological resilience we need in the face of a warming climate. More roads in the backcountry also mean more fires: research shows wildfires are more likely to ignite near roads. Once roads and clearcuts fragment these landscapes, the damage is permanent. Weakening or repealing the Roadless Rule would be a grave mistake. I do not support any of the proposed action alternatives that roll back the Roadless Rule. I urge the USDA to abandon this misguided effort and instead strengthen its commitment to protecting America’s roadless forests for the clean water, climate resilience, recreation, and biodiversity they provide. Leave the Roadless Rule in place. References: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026) https://doi.org/10.1186/s42408-026-00450-2 Mildrexler, D.J., Berner, L.T., Law, B.E. & Both, M.S. Roadless rule rescission threatens highest integrity forest ecosystems in the United States. Biological Conservation 321, 111950 (2026) https://doi.org/10.1016/j.biocon.2026.111950 Sincerely, Soren Gulsrud Longmont, CO 80501 brolo34@gmail.con

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 What I want from public land is simple: no vehicles. I want to immerse myself in nature, to paddle rivers that still function as critical bird and wildlife corridors and need to stay away from vehicles, to look for elk, deer, bears, bobcats, and every seasonal bird the landscape carries. The Roadless Area Conservation Rule protects the conditions that make those things possible, and this administration's proposal to rescind it is something I oppose without reservation. The public is a strong supporter of this rule, and so am I. The wildlife science alone should give the agency pause. I look for elk, and the agency's own record shows that elk avoid areas near roads and select habitat away from them, that elk survival rates rose during a road closure and fell again when the gates were removed. For deer, the DEIS cites Wyoming research finding that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed, disrupting the unroaded security the animals depend on. When I paddle rivers and listen for the seasonal birds those corridors carry, I am relying on exactly the kind of quiet the rule preserves. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The agency has its own numbers. I ask that it explain, on the record, how opening these areas to road construction squares with the documented effects on the species its analysis names. That analysis also documents a fragmentation penalty the agency has declined to apply to its own proposal. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears, and then nothing follows from it. No projection is made across the 40.1 million acres of potentially affected environment. A number that severe, cited in the agency's own document, demands application. I ask that the agency carry the cited fragmentation range across the 40.1 million acres of potentially affected environment and explain why it chose not to do so in the current draft. Roads also lead to invasive weeds, washouts, and other issues that degrade the experience and the land itself. The fire data the agency compiled reinforces this. "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." The agency cannot simultaneously cite that gap and claim road-building reduces fire risk without quantifying the expected increase in human-caused ignitions from new access and weighing it honestly against the claimed hazard reduction. That accounting is missing from the current proposal. Clean water is becoming more and more at risk due to the actions of this administration, and that is absolutely unacceptable. The cost of treating increasingly polluted water falls onto average Americans, not onto the industries that benefit from the roads. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and the agency is already billions behind on maintaining the roads it has. Building new ones into country that has none compounds a burden the public will bear through degraded watersheds and higher treatment costs. The regulatory record has problems that go beyond the substance. "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 is reached by averaging losses 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 of those firms may lose those receipts. The certification should be withdrawn and the impact assessed on the entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, 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. This comment is one such interest. My use of these areas, and my expectation that the rule protecting them would remain in place, is a reliance interest the agency invited and has not addressed. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final action. Sincerely, Jenny Russell Telluride, CO 81435

I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). As someone who lives in Arvada, Colorado, public lands are vital to my community and daily life. I regularly recreate, hike, or find solitude in the national forests in my state. Dismantling the Roadless Rule threatens critical ecosystems, old-growth forests, wildlife habitats, and clean drinking water sources relied upon by millions of Americans. Roadless wildlands also act as natural buffers against severe wildfires and heavy carbon storage, benefits that cannot be easily replaced once fragmented by commercial logging or new road construction. I urge the U.S. Forest Service and the Department of Agriculture to abandon this proposed rollback, honor the original protections established in 2001, and keep these irreplaceable backcountry landscapes intact for future generations. Thank you for the opportunity to comment. Sincerely, Nina Granow Arvada, CO 80004

I find it APPALLING + DISGRACEFUL that you are even CONSIDERING this HORRIFIC act!!! Our National Forest are PUBLIC LAND! That means they belong to ALL AMERICANS NOT billionaires +/or any corporate interests! I DEMAND that you maintain protections for the 45 million acres of wild and roadless forests and don’t rescind or alter the Roadless Area Conservation Rule. These forests are full of mature and old-growth trees that provide important wildlife habitat. They also provide oxygen for all animals + humans! They protect us from the CLIMATE CRISIS PROVEN to be CAUSED by DIRTY FOSSIL FUELS!! Also they’re our favorite places to hike, fish and camp. Wild PUBLIC forests should remain protected from road-building, commercial logging and mining. Remember the CONSTITUTION states that the government MUST PROTECT AMERICANS + the ENVIRONMENT!! Allowing roads + logging does NOT DO THAT!! DO YOUR DAMN JOB AND PROTECT the FORESTS!! Industrial activity would destroy the trees and trails we love + multiple ANIMALS + their habitats. If this is allowed to happen we will NEVER get these FANTASTIC FORESTS BACK or the ANIMALS that live in them. I DEMAND that you KEEP our PUBLIC national forests WILD + STAY AWAY from them FOREVER!! WHAT is WRONG with you people anyway??? REMEMBER AMERICANS ARE WATCHING YOU + WE WILL BE WAITING to see if you are as CORRUPT as this trump regime. We’ll REMEMBER!!! Sincerely, Andrea Schauer 13618 E Bethany Pl Apt 109 Aurora, CO 80014-3691 lalischauer@gmail.com

October 3, 2026 Comments on the proposal to rescind the Roadless Area Conservation Rule. Docket # FS-2025-0001. My name is Suzanne DeVore and I live in Mosca, Colorado at zip code 81146. I am a voter. I am an avid hiker, walker, bicyclist, Nordic and downhill skier, camper and birder. I spend a ton of time every year recreating on public lands. It is my understanding that despite 99% public opposition to its rollback, the Administration moved forward with its intent to rescind the 2001 Roadless Rule by publishing a Draft Environmental Impact Statement (DEIS). I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I strongly support Alternative 1, the No Action alternative. I love spending time in the National Forests near where I live in southern Colorado. Including the Rio Grande National Forest, the San Juan National Forest, the Gunnison National Forest and the San Isabel National Forest. I am fortunate to be able to walk to the Sangre de Cristo Wilderness from my home. I also spend weeks camping in the neighboring state of Wyoming. I particularly love the Medicine Bow National Forest and the dramatic Snowy Range in southern Wyoming. I also love to camp in the Bighorn National Forest and backpack in the Wind River Range. My husband is an avid fly-fisherman, so this determines a lot of the places we visit! We like to travel to the Coronado National Forest in Arizona for hiking and cycling during the winter. We particularly love the areas in and around the Chiricahua mountains. This proposal is just ludicrous for many reasons, but mainly because the current road system is stressed now! The U.S. Forest Service lacks the capacity, in funds and workforce, to support its existing roads, much less an increased inventory of roads. There are plenty of roads now. Roads cause excessive erosion and siltation to streams. Most of America's clean, fresh watersheds start in national forests. In this time of changing climate and severe droughts the current rule protects our valuable drinking water. Roadless areas help keep invasive species at bay and prevent pollution. The DEIS details many points on this topic. The current rule protects intact ecosystems for American wildlife. Roadless areas provide habitat for vulnerable wildlife species, including the Canada Lynx in our area. These roadless landscapes, often adjacent to other protected areas, like wilderness, are critical for habitat connectivity and health. Roads severely impact birds and wildlife. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird variety and abundance. It is vital to avoid fragmentation of the roadless areas. The DEIS cites the finding that habitat fragmentation reduces biodiversity. Wildlife tend to disappear when forest cover thins; many avoid roads used by winter machines. The DEIS notes that wide-ranging mammals like the grizzly bear “have suffered habitat loss and the extirpation or fragmentation of their populations.” It is false that building more roads will help fight wildfires. Studies show that more roads do not lead to better forest health through increased fire-management activity. Conversely, Wildfire incidents happen near roads. Studies show that 90% of wildfires happen within 1/4 mile of roads. If more roads led to more fires, this action would increase the number of incidents, not improve response, as suggested. Our National Forests sustain some of our nation’s last stands of old growth forest. Here in Colorado our nearby Rio Grande National Forest and all the national forests across the United States are an economic boon for tourism and for well-planned and regulated timber sales. No new roads are required to support these benefits of the forest. It is widely recognized that the purpose of changing the roadless rules has nothing to do with forest health as it is proclaimed to do. The purpose is to reduce regulatory burden and return decision making to local officials, not U.S. Forest Service experts with years of education and experience managing our forests for all U.S. citizens. This proposal is a callous, greedy attempt to provide access to our public lands for oil, mining, timber and other extractive industries! It’s sacrificing our forests to make a few wealthy elite people richer. It would bring short-sighted and short-term benefits to these few, while ruining long-term, irreplaceable lands that belong to all of us, the public. I completely oppose the proposal to rescind or alter the Roadless Rule, and strongly support Alternative 1, the No Action alternative. Suzanne DeVore 113 Spring Creek Drive Mosca, CO 81146

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

Urgent: Maintain the Roadless Rule to Protect Wildlife and Wildlands (1) Introduction: Why This Matters I’m a backpacker, conservationist, and advocate for wildlife deeply concerned about threats to our roadless areas. Having spent years exploring these lands, I’ve seen how roads fragment habitats, invite invasive species, and escalate human-caused disasters. The Roadless Rule is essential to preserving what remains of our wild heritage. Repealing it would accelerate ecological collapse and endanger species already struggling to survive. (2) Background: What’s at Stake The Roadless Rule (2001) protects 58.5 million acres of inventoried roadless areas on national forests from logging and road construction. These areas are critical for biodiversity, clean water, carbon storage, and recreation. Yet, recent attempts to weaken or repeal the rule ignore science and public interest. (3) Analysis: Why Repealing the Rule Is a Disaster A. Roads Destroy Wildlife Roadkill is a leading cause of death for deer, elk, bears, and amphibians. Source: U.S. Fish & Wildlife Service (2021) Fragmentation isolates species like wolves and wolverines, pushing them toward extinction. Source: Nature Conservancy (2020) Invasive species spread along roads, outcompeting natives. Source: USDA Forest Service (2019) B. Roads will equal More Human Disasters 90% of wildfires are human-caused, and roads increase access for careless behavior (e.g., campfires, target shooting). Source: National Interagency Fire Center (2023) Motorized vehicles degrade trails, disturb wildlife, and pollute waterways. Road construction itself is ecologically destructive (deforestation, erosion, sediment runoff). C. The Rule Doesn’t Ban Access—It Bans Destruction The Roadless Rule does not block recreation. It only prohibits roadbuilding and logging, allowing: Hiking, hunting, fishing, and horseback riding Scientific research and cultural practices Controlled burns for restoration Repealing it would prioritize short-term profits over long-term survival. D. Economic and Climate Costs of Weakening the Rule Roadless areas generate $1.1B annually for local economies via tourism. Source: Headwaters Economics (2022) Undisturbed forests store more carbon, combating climate change. Clean water from roadless watersheds serves millions downstream. (4) Recommendations The Forest Service must: A. Keep the Roadless Rule intact—no exemptions for logging/roads. B. Enforce protections against illegal road construction and off-road vehicles. C. Expand roadless designations in critical wildlife corridors. D. Invest in sustainable access (e.g., trails, shuttles) instead of roads. (5) Conclusion: A Plea to Protect Our Last Wild Places The Roadless Rule is not a barrier to access—it’s a safeguard for the future. It protects: Species on the brink (grizzlies, lynx, migratory birds). Clean water and air for communities. Climate resilience by preserving carbon sinks. Recreation opportunities for generations to come. Repealing this rule would be a historic mistake. I urge you to defend it fully and strengthen protections for our roadless wildlands. Sincerely, Christa Chagra 60 Lilac Court Pagosa Springs, CO 81147

As a person who appreciates the many values national forests bring to my state, my wellbeing, our wildlife and more, I support Alternative 1: The “No action alternative” because we should keep the Roadless Rule intact. Roadless areas keep our forests healthy. They serve as the ecological backbone of our national forest lands and: - Supply 50% of California’s drinking water - Support Tribal cultural practices - Enhance outdoor recreation including backcountry hiking, backpacking, horseback riding, mountain biking, camping, angling, and hunting - Shelter over 200 imperiled species like the Pacific fisher and Sierra Nevada red fox - Protect the military mission in part by serving as a crucial buffer against urbanization. And, more roads mean more wildfire risk. Most wildfires are caused by humans and most human-caused fires occur near roads. We don’t need more. Please move forward with the No Action Alternative 1: Keep the Roadless Rule intact. I believe wildlands need to be left completely natural to not disturb natural processes. Please support the Roadless Rule. Sincerely, Ericka Abrams Aurora, CO 80015

Dear Secretary Rollins, I use the outdoors every week with my family and friends and it is abhorrent that the Roadless Rule is being attacked. Listen to your constituents and keep the wilderness wild. Sincerely, Nell Taylor Pagosa Springs, CO 81147 nellataylor19@gmail.com

Dear Secretary Rollins, As a human being, a father, an Appalachian Trail, Pacific Crest Trail and Colorado Trail thru hiker, I strongly oppose the USDA’s proposal to eliminate or weaken the Roadless Rule. This reckless action would devastate public lands, waste taxpayer resources, and undermine the water, wildlife habitat, and recreation opportunities on which millions of Americans depend. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean drinking water, provide refuge for vulnerable species, and serve as critical carbon sinks critical to mitigating the worsening impacts of climate change. People hike, forage, bike, fish, camp, ski, climb, and find solace in these remote places. Roads spread invasive species, fragment wildlife habitat, and erode the very ecological resilience we need in the face of a warming climate. More roads in the backcountry also mean more fires: research shows wildfires are more likely to ignite near roads. Once roads and clearcuts fragment these landscapes, the damage is permanent. Weakening or repealing the Roadless Rule would be a grave mistake. I do not support any of the proposed action alternatives that roll back the Roadless Rule. I urge the USDA to abandon this misguided effort and instead strengthen its commitment to protecting America’s roadless forests for the clean water, climate resilience, recreation, and biodiversity they provide. Leave the Roadless Rule in place. References: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026) https://doi.org/10.1186/s42408-026-00450-2 Mildrexler, D.J., Berner, L.T., Law, B.E. & Both, M.S. Roadless rule rescission threatens highest integrity forest ecosystems in the United States. Biological Conservation 321, 111950 (2026) https://doi.org/10.1016/j.biocon.2026.111950 Sincerely, Wylie Jones Conifer, CO 80433-9626 wyliedread@gmail.com

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The San Miguel and Dolores Rivers run through some of the most intact country left in Colorado, and I have spent the past decade visiting the Tabeguache and the Cimarron on the Grand Mesa-Uncompahgre-Gunnison National Forest. Losing these spaces would be devastating for the people of Colorado and the people of the West. I oppose the rescission of the 2001 Roadless Area Conservation Rule. Public lands should be managed to protect them for future generations. That principle is directly at stake here, and I want to address what I have seen and what the agency's own record shows. I paddle the San Miguel and Dolores Rivers and their tributaries. Those rivers drain the kind of unroaded country this rule protects. Roads change hydrology, increase erosion, and degrade the water quality that paddlers and downstream communities depend on. Colorado holds 326 inventoried roadless areas totaling 4,407,277 acres, and across the Rocky Mountain region 325 municipal water intakes sit in watersheds containing affected roadless areas. That is not an abstraction. It is the water in these valleys. The wildfire situation in the Cimarrons is not abstract either. I have watched wildfires rage around the Cimarrons this past summer. It took extensive resources to keep homes and communities safe. The agency argues that rescission supports fuel management, but its own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Adding more roads to a region already experiencing these fires poses a much larger risk to wildfires spreading and posing a greater threat. The agency must explain why this proposal departs from its own prior findings, and it must reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside affected roadless areas. The fire rationale also does not match the stated legal basis for this action. The agency's own record acknowledges: "The purpose and need is to reduce regulatory burden and return decisionmaking to local officials. Overlap with the wildland-urban interface as defined by HFRA is 9.8 million acres, 24 percent of the affected area, and the DEIS says the benefits of added fuel-management access 'would likely be modest and localized.'" The agency built and then rejected a WUI-targeted alternative that would have answered the fire rationale without nationwide rescission. Why was that alternative discarded in favor of a blanket rollback? The agency has not answered that question. On the economics: it absolutely does not make sense to spend more money constructing roads when existing roads cannot be maintained. Southwestern Colorado is already experiencing mudslides and environmentally destructive events more and more often. The Forest Service cannot maintain roads, bridges, and access points in the appropriate timeframe, and the USFS in our region will not be able to manage more roads and more terrain going forward. The agency is already $6.9 billion behind on maintaining the roads it has, against a road budget of about $73 million a year. 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 must reconcile the proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain how an action whose own numbers cannot establish a net benefit justifies expanding a road system already collapsing under deferred maintenance. Finally, the alternatives analysis is broken at its foundation. The agency's record acknowledges: "Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it 'would continue to restrict local decision-making discretion' and because analysing roadless values is 'an administrative and legal burden for the agency.'" A purpose written as deregulation forecloses the comparison NEPA requires. The agency must restate the purpose and need in terms of actual forest conditions and analyze at least one fully protective alternative before this rulemaking proceeds further. The Tabeguache and the Cimarron matter. The rivers that run out of them matter. Protect them. Sincerely, Marisa Marshalka Telluride, CO 81435

Subject: Public Comment Opposing the Proposed Rescission of the Roadless Area Conservation Rule (Docket ID: FS-2025-0001 / RIN: 0596-AD66) Dear Chief Moore and U.S. Forest Service Officials, I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Rule. Having personally backpacked and hiked in many of our nation’s roadless national forests across the West—including the rugged peaks of Colorado, the lush backcountry of Washington and Oregon, and the diverse ecosystems of California—I know firsthand the irreplaceable ecological, economic, and spiritual value these intact wild lands provide. I urge the Forest Service to maintain current protections, a position strongly supported by recent agency data and independent scientific studies. My opposition is rooted in several critical areas of concern, backed by clear evidence: Severe Impacts on the Outdoor Recreation Economy & Outfitters: Roadless areas are the backbone of America’s outdoor recreation infrastructure. According to the Forest Service's own DEIS, repealing the Roadless Rule is projected to cause a minimum of $6.1 million in annual losses to recreationists and $9 million in lost recreation visitation expenditures. Local guides, outfitters, and communities depend heavily on what the DEIS acknowledges as opportunities for “quiet, remote and self-reliant recreation”. Forcing these small businesses to absorb millions in losses to support negligible logging increases—which the agency admits takes place on less than 1% of operable areas annually—is fiscally and socially irresponsible. Disruption of Critical Wildlife Migration & Habitats: National forests serve as vital sanctuaries, but fragmentation from road building threatens population viability. A comprehensive study published by the Center for Biological Diversity reveals that dismantling these protections overlaps with critical habitat ranges for over 400 imperiled animal and plant species. Across Colorado, Washington, Oregon, and California, these roadless lands provide irreplaceable contiguous migration corridors for large mammals like elk, mule deer, bighorn sheep, and wolves. Furthermore, mapping research published in Biological Conservation utilizes a "forest integrity score" demonstrating that unroaded forests maintain significantly higher biodiversity and ecosystem resilience. Fragmenting these continuous corridors with industrial roads will irrevocably bisect wildlife home ranges and accelerate localized extinctions. Increased Human-Caused Wildfire Risks: While the proposal cites wildfire preparedness as a justification for access, scientific data demonstrates the opposite outcome. Peer-reviewed analyses confirm that wildfires are four times more likely to start in areas served by roads than in roadless areas, with roughly 90% of all wildfires on national forests starting within a half-mile of a road. Introducing new roads into the vulnerable, fire-prone backcountry forests of California and the Pacific Northwest will drastically increase human activity and, consequently, human-caused wildfire risks to nearby communities. In this year alone, 14 wilderness firefighters have lost their lives fighting forest fires. Please don't increase this number by building more roads which will result in more fires. Loss of Watershed Integrity: I am deeply concerned about downstream impacts of this proposed decision. Research led by the University of Washington shows that the Roadless Rule currently protects the clean drinking water supply for 25 million Americans across 80,000 miles of rivers. Stripping protections will degrade pristine watersheds that feed major municipal systems—from the Colorado River headwaters to the critical salmon-bearing rivers of Oregon and Washington—forcing municipal water utilities to pass expensive filtration and treatment costs onto taxpayers. Rescinding the Roadless Rule swaps permanent, multi-billion-dollar ecosystem services for minimal, short-term commercial extraction. Specifically, the U.S. Small Business Administration estimates that the increase in the timber harvest that would result from the abandonment of the Roadless Rule would generate $4.6-10.6 M a year in increased timber industry revenue. This revenue increase falls far short of offsetting the decline in the recreation and tourism revenue that will accompany the change- $16M+) ---let alone compensate for the destruction of wildlife habitat, increased forest fires and reduced clean water for 25 million americans Having experienced the solitude and untamed beauty of these roadless landscapes across Colorado, Washington, Oregon, and California, I urge the Forest Service to heed its own impact analyses and the broader scientific community by upholding the 2001 Roadless Rule. Thank you for your time and for considering my comments. Sincerely, Kenneth C. Dunn, Boulder, CO 80302[

I am writing to oppose ending the roadless rule. I live near the GMUG National Forest in Western Colorado. I have experienced many wildfire seasons. In 2020, I started wearing a mask as needed. I recently learned that wildfire smoke picks up many more toxins that make us sick, so I continue to wear a mask as needed. There are already laws on the books that let roads be built in roadless areas as needed to prevent wildfires, so that excuse doesn't work! And the feds will make more money off hunting and recreation in roadless areas than opening it to logging. None of the lame excuses to opening the roadless area hold any water! PLEASE let the trees stand. They create the AIR that we all breathe!!!! Thank you, Nancy Wicks 2 Pan American Ave Paonia, CO 81428

Hello USDA forest services, I live in Greeley, CO 80631 and I am against repealing the Roadless Rule. I am against repealing the Roadless Rule because ecosystems will be disturbed negatively affecting hundreds of animals, plants, trees, lands, and waters. Repealing this rule will contribute to the loss of species and harm our clean water. Repealing the Roadless Rule will also decrease spaces for hiking, camping, hunting, and fishing disrupting recreational access and therefore reducing opportunities to generate income through nature-based tourism.

I am writing to strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Our national forests are a public inheritance that should be protected for future generations. Roadless areas provide important wildlife habitat, clean water, opportunities for hunting, fishing, hiking and other recreation, and large landscapes that remain relatively undisturbed by development. I recognize the need for responsible forest management, including appropriate wildfire mitigation and protection of nearby communities. However, I do not believe eliminating nationwide Roadless Rule protections is necessary to accomplish those goals. Once roads are constructed and previously undeveloped areas are fragmented, restoring their roadless character can be difficult or impossible. Please retain the 2001 Roadless Area Conservation Rule and continue protecting these valuable public lands while using carefully targeted forest-management practices where they are genuinely needed. Thank you for considering my comments. Sincerely, Patrick Madison PO Box 287 Golden, CO 80402 720-398-7991

Director, Ecosystem Management Coordination 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 Special Areas; Roadless Area Conservation Proposed Rescission of the 2001 Roadless Rule. Subject: Oppose rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66 / Docket FS-2025-0001) To the U.S. Department of Agriculture and U.S. Forest Service: I am writing as a private citizen and outdoorsman who hunts, fishes, and spends time on National Forest lands. I live in the Denver metro area of Colorado. I oppose the proposed rule to rescind the 2001 Roadless Area Conservation Rule in its entirety. I understand the stated purpose: reduce regulatory burden, return decisions to local forest plans, and make it easier to treat fuels and lower wildfire risk. Those are serious goals. They do not require tearing down the national floor that has kept inventoried roadless areas from becoming a default road-and-harvest landscape. What these lands actually provide Inventoried roadless areas are not leftover scraps. They are some of the last large, unroaded blocks on the National Forest System. They hold intact watersheds, cold-water fisheries, and the kind of security cover elk, mule deer, and bear actually use. Analyses used by hunters and anglers show very high overlap between roadless acres and big-game habitat. That is not an abstraction to people who walk those drainages. Roads change the country. They fragment habitat, put sediment in streams, spread weeds, and make it easier for people - and ignition sources - to get farther into the timber. Wildfires are more likely to start where roads already exist than in roadless tracts. Opening more of these acres to construction does not automatically produce healthier forests. It produces more linear disturbance and a larger maintenance bill the Forest Service already cannot keep up with. Taxpayers have carried an enormous road-maintenance backlog for decades. Building more miles into country that has stayed roadless for a reason is not fiscal discipline. The rule is not a total lockout The 2001 rule already allows limited exceptions, including certain hazardous-fuels work, stewardship, and other management. If the problem is that those exceptions are too narrow or too slow, the honest fix is to amend the exceptions and fund the work - not delete the prohibition and hope every forest plan holds the line. Rescission does not require cutting or roadbuilding, but it removes the national constraint. Once that constraint is gone, pressure for timber, minerals, and access will fall on individual supervisors with fewer tools to say no. Colorado context, and why a national rule still matters Colorado has its own Roadless Rule. That state rule is not on the chopping block in this proposal, and I am glad of it. That does not make the national rescission harmless. I use National Forests beyond Colorado. Fish, wildlife, and water do not stop at state lines. A national repeal on the remaining 45 million acres sets the template for how local flexibility will be used everywhere the 2001 rule still applies, including Alaska’s Tongass and forests I travel to for fishing and backcountry time. A floor that took years of hearings and more than a million comments to build should not be removed in a short comment window with no comparable public process. Last year’s scoping already produced hundreds of thousands of comments, the large majority opposed to repeal. That record should count for something. A 30-day period, even extended to October 6, is not a substitute for the process that created the rule. What I am asking you to do 1. Withdraw the proposed rescission of 36 CFR part 294, Subpart B. 2. Keep inventoried roadless areas under a national prohibition on new road construction and most timber harvest, with tightly written exceptions for genuine fuels reduction, public safety, and stewardship that can be done without a permanent road system. 3. If fuels treatment is the driving need, fund and prioritize work in the wildland-urban interface and already-roaded acres first - the places where homes, infrastructure, and existing access already concentrate risk - rather than treating unroaded backcountry as the default treatment unit. 4. Do not treat “return decisions to the forest plan” as equivalent to protection. Plans change. A national rule is the only durable check most of these acres have. I am not opposed to active management. I am opposed to confusing management with a permanent road network in the last unroaded national forest country we still have. Once a road is in, the place is not roadless anymore. That change does not reverse on a planning cycle. Please retain the 2001 Roadless Area Conservation Rule. Respectfully, Leo Sands Wheat Ridge, CO 80033 Leo.Sands42@gmail.com

Dear Special Areas: Roadless Area Conservation, WTF! Iran can just sit back and watch my country implode from within. This is part of a pattern of deconstructing what nature has built and destroying what really makes America beautiful. I urge the U.S. Forest Service to keep intact the existing Roadless Area Conservation Rule (“Roadless Rule”), which protects nearly 45 million acres of our nation's forests and grasslands. We have made our opinion clear time and time again–our public lands should remain public, not be degraded for the interests of private industry. I strongly urge the U.S. Forest Service not to repeal the Roadless Rule, as keeping the rule intact will protect our shared forestlands for generations to come. Steve Shaffer 3725 East 15th Street, CO 80538 Sincerely, Steve Shaffer

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The wildness my kid should be able to explore and see in its old-growth, untouched state is what this comment is really about. I paddle rivers and lakes, I have lived through fire seasons that were terrible and scary and hard to breathe through, and I am filing this comment because rescinding the 2001 Roadless Area Conservation Rule would damage things that cannot be put back: not the water, not the carbon, not the silence that keeps animals from being pushed into towns. The agency's own effects document states that these inventoried roadless areas contain a significant share of the nation's stored carbon: "The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons." The document then concludes that carbon sequestration will continue without providing any analysis of what happens to that figure when timber harvest and roading are authorized under subsequent plan amendments. That is not analysis; it is an assertion dressed as a conclusion. I ask the agency to quantify what happens to stored carbon and sequestration rates under each alternative, including scenarios in which harvest and road construction expand. The question of those plan amendments is itself a procedural problem that compounds the carbon gap. The proposed rule concedes 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 (91 FR 53830). The agency cannot simultaneously declare the foreseeable consequences of this action out of scope and ask the public to comment on them. The analysis of expanded timber harvest area belongs inside this action, not deferred to future proceedings where the structural protection will already be gone. I ask the agency to treat the foreseeable plan-amendment scenario as part of this rulemaking and to analyze it accordingly. The agency also owes the public an explanation for reversing its own prior factual conclusion. The proposal asserts that local land management planning now adequately protects roadless values; in adopting the 2001 rule (66 FR 3244) the agency found the opposite, that local planning had allowed those values to be reduced piece by piece and that their national significance required a national rule. An agency is entitled to change course, but it must explain what changed and why the prior finding no longer holds. The proposal does not do that. It substitutes the assertion for the reasoning. I ask the agency to identify the specific evidence that supports reversing the 2001 finding and to engage directly with its own prior conclusion rather than simply displacing it. On fire, the agency's own data argue against this proposal in terms the agency does not adequately confront. 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. I have seen fire seasons. I know what it means when animals are stressed out of their habitat and into towns, when the air becomes hard to breathe, when the landscape that is supposed to be left alone is instead destabilized. The agency's own numbers show that roads bring ignitions, and ignitions bring exactly the kind of fire seasons I have described. The effects analysis does not quantify the expected increase in human-caused ignitions that would follow from new road access, nor does it weigh that increase against whatever wildfire-hazard reduction the proposal claims. The agency must do that work before this rule moves forward. Without these places, we lose something that defines the United States. A road does not grow back. The rule that took more than 600 public meetings and 1.6 million comments to build is being undone without a single public meeting held. The waters I paddle, the old-growth wildness I want my kid to see, and the animals that live in these areas deserve the analysis this proposal has skipped. I oppose rescission and ask the agency to address each of these failures in the record. Sincerely, Emma Kottenstette Hotchkiss, CO 81419