FS-2025-0001-564301

First, PLEASE keep the Roadless Rule in place. The Roadless Rule has been in place for a quarter century, sustaining landscapes that contribute to people’s livelihoods and sanity. Such a draconian change to the status of Roadless public lands, as is being proposed by the current administration, is destabilizing not only to people but to the environment and the ecosystem services it provides. Forests protected by the2001 Roadless Rule -- adopted with overwhelming public support -- provide vital habitat for thousands of wildlife species, safeguard drinking water supplies for millions of Americans, and ensure quality recreation cherished by all. The Roadless Rule was enacted in 2001 after more than 600 public hearings were held around the nation, and the public provided more than 1.6 million comments on the Rule—more comments than any other rule in the nation's history. It is shameful that public hearings were not scheduled at all for a situation that will affect millions of Americans – and the thousands who come from other countries just to experience the amazing thing that we in American have: PUBLIC LANDS!!! Because of their special qualities, maintaining roadless areas has been a goal of conservation for nearly 90 years (Marshall, R., & Dobbins, A. (1936). Largest roadless areas in the United States. The Living Wilderness, 2, 11–13.) Roadless designation does not preclude management activity. In Montana alone, since the 2001 Roadless Rule went into effect, more than 188,400 acres of hazardous fuels treatments have been conducted in roadless areas. These roadless lands are critical to the health of our elk populations in Montana. 93% of summer elk habitat is within roadless areas. Roadless lands are the secure habitat that provides a 5-week elk seasons in Montana. Montana's five-week hunting season generates significant revenue for the state, contributing approximately $118 million. Overall, outdoor recreation, including hunting, plays a crucial role in Montana's economy, accounting for a substantial portion of the state's GDP. Withdrawing the roadless rule would require the shortening of Montana’s elk season to the detriment of all elk hunters, and to the economy of the state. Roads negatively impact trout and trout streams through sediment, pollution, and altered stream channels. 79% of roadless lands in Montana are home to native trout like Westslope cutthroat trout, bull trout, and Yellowstone cutthroat trout. The mountainous terrain of Montana's roadless areas, particularly Inventoried Roadless Areas (IRAs) in national forests, contains the headwaters for many of the state's major river systems. The high elevation of these areas means they receive a disproportionate amount of precipitation and snowpack, which is critical for year-round streamflow. However, with about 7,000 miles of dirt roads on national forest lands contributing sediment to waterways in Montana, this figure would expand dramatically if the Roadless Rule were abandoned. Roadless lands provide secure areas from human-caused forest fires because 78% of human-caused fires on USFS lands occur within a half-mile of a road. 85% of all wildfires are human-caused. As a result – there are far fewer fire starts within Roadless lands, than in areas penetrated by roads. More than 90% of roadless areas in Montana are recognized as having low or very low potential for energy development. The 2001 roadless rule recognizes valid existing rights for oil and gas development, and it does not prohibit new leases. USFS currently has $8.6 billion in deferred maintenance on existing USFS roads. This means the USFS cannot come close to maintaining all the roads they currently have, never mind building new roads. More than most states, with rescission of the Roadless Rule, Montana has the most to lose with respect to clean water, wildlife habitat, hunting opportunity, and long-term economic prosperity. Thousands of Montanans weighed in on the Roadless issue 25 years ago, and to this day people overwhelmingly support Roadless designations. As a life-long hunter, wildlife biologist, Montana native, and board member of Helena Hunters and Anglers Association and past-president of the Montana Chapter of The Wildlife Society – all of which have supported the Roadless Rule, I respectfully implore you to keep the Roadless Rule in place, or better yet, enshrine these roadless lands in permanent legal protection. For the past six years, as a member of the Helena Hunters and Anglers Association, I and others have been gathering and reporting on the status of Inventoried Roadless Areas on the Helena portion of the Helena-Lewis and Clark National Forest. Photo records, field notes, and aerial reconnaissance have so far, documented the status of five Inventoried Roadless Areas -- noting where the landscape is functioning well and where improvement could be implemented. One of these reports is attached.