FS-2025-0001-591710

To the Department of Agriculture: I grew up in Montana, and have worked for the Forest service in multiple capacities as well as numerous years of recreating in Wild areas across the United States. For a person who has sought out roadless public land across different regions and in different seasons, I'd say the 2001 Rule is one of the clearest expressions of what the public land system is supposed to protect — and rescinding it would be a clear statement about what it isn't. I grew up exploring places like the Crazy Mountains as well as others nearby. My wife and I recently hiked to the blue lakes, where we were able to access an alpine area filled with unique wildflowers with no other person in sight. Places accessible only by foot, that are protected from destruction by bulldozers and tires Regarding the Crazy Mountain in the Gallatin National Forest, Montana: Alpine and Subalpine Climate Refugia — The area's high-elevation ecosystems—Rocky Mountain Alpine Turf, Alpine Dwarf-Shrubland, and Whitebark Pine/Subalpine Fir Woodland—occupy the summits and ridges of peaks exceeding 10,700 feet and represent climate refugia where species can persist as lower-elevation habitats warm. Whitebark pine, a federally threatened species and IUCN-listed endangered species, depends on these high-elevation zones where it grows in association with subalpine fir; the species is already declining across the West due to white pine blister rust and mountain pine beetle. Road construction at high elevations would remove the canopy structure that whitebark pine requires and would increase human access that spreads invasive pathogens, directly undermining recovery prospects for this species in one of its remaining strongholds. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. “Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2)” The Department's obligation under the APA is to provide reasoned explanation commensurate with the significance of the policy change; that obligation has not been met, and rescission should be denied. All the best, CommentID: RLC-20261006-E8VZJB