I. The Forest Service Has Not Demonstrated That Wholesale Rescission Is Necessary

The stated purpose and need is to reduce regulatory burden, return decision-making to local Forest Service officials, increase management flexibility, and allow active management in response to wildfire, insects and disease, and community protection needs. DEIS at 10-12. Those objectives do not, however, establish that eliminating the Rule across approximately 44.7 million acres is necessary.

The DEIS acknowledges that the existing Rule contains exceptions for public health and safety, reserved and outstanding rights, certain mineral leases, prevention of resource damage, and stewardship activities. It also allows cutting and removal of generally small-diameter timber to improve habitat for threatened, endangered, proposed, or sensitive species and to maintain or restore ecosystem characteristics, including reducing the risk of uncharacteristic wildfire effects. DEIS at 6, 13-14.

The agency's own implementation data further undercuts the premise that the Rule prevents meaningful management. The DEIS reports approximately 1.8 million acres of hazardous-fuels reduction in inventoried roadless areas over the last decade and approximately 500 acres per year of timber harvest during this period. It also states that prescribed fire is not prohibited, and that hazardous-fuels reduction has occurred on roughly five percent of the potentially affected IRA area in the last decade. DEIS at 7, 94-96.

Before eliminating a nationwide conservation standard, the Forest Service should demonstrate why existing exceptions, improved administration of those exceptions, targeted amendments, or a more narrowly tailored rule cannot meet specific management needs. The DEIS does not explain why these less sweeping approaches would be insufficient.

II. The Purpose and Need and Range of Alternatives Are Too Constrained

NEPA requires an EIS to evaluate a reasonable range of technically and economically feasible alternatives that meet the proposal's purpose and need. 42 U.S.C. § 4332(2)(C)(iii), (F). Although agencies receive substantial deference in determining the scope and the level of detail appropriate for an EIS, that discretion remains bounded in NEPA’s requirement to consider reasonable alternatives. See Seven County Infrastructure Coalition v. Eagle County, 605 U.S. 168 (2025).

The DEIS analyzes three principal alternatives: the existing Rule, complete rescission, and Alternative 3, which removes Roadless Rule prohibitions in the wildland-urban interface and within one-half mile of existing roads while retaining protections elsewhere. DEIS at 13-18. The Forest Service’s Alternative 3 mapping likewise describes the roaded-roadless component as a half-mile buffer around existing roads. The agency considered, but eliminated from detailed study, an alternative that would maintain existing IRA boundaries and the prohibition on permanent road construction while allowing temporary roads and timber harvest. The stated reason is that it would continue to constrain local discretion and require project-level consideration of roadless values, which the agency characterizes as an administrative and legal burden. DEIS at 28.

That rationale illustrates the concern with the current purpose and need: if any alternative that retains meaningful national constraints is deemed inconsistent with the purpose and need because the purpose is itself to eliminate national constraints, the purpose and need predetermines the range of alternatives. GYC requests detailed analysis of an alternative that retains the national Roadless Rule as the conservation baseline while improving narrowly tailored mechanisms for temporary access, scientifically justified restoration, hazardous-fuels treatment near communities and infrastructure, and other demonstrated management needs. Alternative 3 confirms that more targeted approaches are feasible, however it goes too far in its overreach of quantifying acres it calls part of the wildland-urban interface and acres open to timber harvest in proximity to roads. The agency should evaluate whether an even more conservation-protective version can meet legitimate management needs without exposing all IRAs to the broader risks of complete conservation loss in Alternative 2 or the extensive overreach of lost conservation outcomes associated with Alternative 3.

III. The DEIS Does Not Adequately Analyze the Impacts of Removing the Rule Will Have on The Conservation Baseline

NEPA requires analysis of the reasonably foreseeable environmental effects of the proposed action, including adverse effects that cannot be avoided. 42 U.S.C. § 4332(2)(C)(i)-(ii). It also requires agencies to use reliable data and resources. 42 U.S.C. § 4332(2)(D)-(E). The 2001 Rule functions as a consistent national conservation floor across covered national forests. Rescission would remove that uniform baseline and leave the level of protection to forest plans and future project decisions, which can vary substantially from forest to forest. The Supreme Court's Seven County decision emphasizes that NEPA analysis should focus on the proposed action under agency review. Here, the proposed action is the Forest Service's own nationwide removal of restrictions on roads and timber harvest, and the foreseeable road-building and timber-harvest effects identified in the DEIS are directly connected to that action and remain within Forest Service authority. See Seven County, 605 U.S. at 176-81.

The DEIS acknowledges that road construction and timber harvest are reasonably foreseeable to increase under Alternatives 2 and 3, but states that the locations and amounts are uncertain and therefore describes many effects in general, programmatic, and qualitative terms. DEIS at 22. Yet the agency has substantial information available to support more refined analysis. For example, the DEIS estimates that current land management plans generally allow timber harvest across approximately 13.4 million acres and road construction across approximately 18.2 million acres of the Roadless Affected Environment. DEIS at 116.

Given the scale of the proposed action, the Forest Service should provide region-, state-, and forest-level analyses identifying where removal of the national prohibition would materially change management possibilities; where roadless lands overlap high-value watersheds, wildlife connectivity areas, migration habitat, and listed-species habitat; and where current forest plans provide protections that are weaker than the Roadless Rule. The repeated statement that future projects will undergo project-level NEPA, ESA, NHPA, land-management-plan consistency review, and tribal consultation does not substitute for analysis of the consequences of the programmatic decision being made now. Future project review may reduce or mitigate individual project effects, but it will occur only after the national conservation baseline has been removed. The final EIS should analyze that baseline change directly.

IV. The Wildfire Rationale Is Not Supported by a Sufficiently Quantified Comparison of Benefits, Risks, and Existing Management Flexibility

GYC supports science-based forest restoration and targeted hazardous-fuels treatments where they can reduce risk to communities, infrastructure, drinking-water sources, and important ecological resources. The relevant question is not whether active management can ever be useful; it is whether wholesale rescission of the Roadless Rule is needed to accomplish that work.

The DEIS acknowledges that the Roadless Rule does not prohibit prescribed fire, provides exceptions for some timber cutting to reduce wildfire risk, and has allowed substantial fuel-reduction work. It further cites research concluding that the Rule did not meaningfully constrain hazardous-fuels treatments when treatments are considered as a share of forested land. DEIS at 94-96.

The DEIS also recognizes countervailing risks that complicate the claim that recission will reduce wildfire risk. It reports that increased road density is associated with increased probability, number, and frequency of human-caused wildfire ignitions. DEIS at 101-102. For example, 90% of wildfires burn within half a mile of a road, and 88% of wildfires are human-ignited. The logic of cumulative causation unequivocally leads to believe building more roads will contribute to more human-ignited wildfires. At the same time, the agency states that, although lifting road restrictions could expand treatment options, high road-building costs and declining road construction and maintenance budgets mean the overall increase in treatment capacity would be modest. The DEIS does not quantify the amount of wildfire-risk reduction expected from Alternative 2. DEIS at 225. These findings warrant a more explicit comparison of the incremental fuels-treatment benefits of rescission against the ignition risks associated with additional roads and access.

The final EIS should quantify, to the extent reasonably possible, how much additional treatment is expected to occur because of rescission; where those treatments would occur relative to communities, high-priority firesheds, and drinking-water-source watersheds; what portion could occur under existing Rule exceptions; and how increased human-caused ignition risk changes the net wildfire-risk picture. The DEIS itself notes that only about 14.8 percent of the affected environment overlaps Community Wildfire Risk Reduction Zones and about 24 percent overlaps the HFRA wildland-urban interface. DEIS at 93-94. These data support a targeted approach rather than nationwide repeal. GYC recommends that the FS retain the Roadless Rule under Alternative 1 and provide clarification to resource managers about implementing actions the wildland-urban interface that are authorized within the exceptions to the Rule.

V. Rescission Would Increase Risks to Wildlife Habitat, Migration, and Landscape Connectivity in the Greater Yellowstone Ecosystem

Large, intact, relatively undeveloped landscapes are essential to biodiversity and the ecological function of the Greater Yellowstone Ecosystem. Inventoried roadless areas support secure habitat, seasonal ranges, migration corridors, dispersal habitat, and connectivity for wide-ranging species. The DEIS itself identifies roadless characteristics that include habitat for threatened, endangered, proposed, candidate, and sensitive species and species dependent on large undisturbed areas. DEIS at 6.

The DEIS further acknowledges that increased road construction, reconstruction, and timber harvest can cause habitat loss and degradation, habitat fragmentation and loss of connectivity, barriers to movement, dispersal and migration, and increased human disturbance. It states that these effects can affect migratory species, game species, terrestrial species, and aquatic species. DEIS at 158-159. In the GYE, these impacts are particularly relevant to grizzly bears, elk, mule deer, pronghorn, bison, native trout, and other species dependent on intact habitat and movement pathways. The final EIS should include a spatially explicit analysis of affected IRAs in Montana and Wyoming that overlap known or modeled wildlife migration routes, seasonal ranges, grizzly bear secure habitat and linkage areas, and important aquatic strongholds. National averages obscure the ecological importance of specific GYE landscapes and do not adequately disclose the consequences of removing protections from those areas.

Grizzly Bears

For example, secure habitat unencumbered by human development, especially roads, is critical to the long-term viability of grizzly populations. Motorized route management is a necessary conservation measure for addressing key threats to grizzly bear survival. The Roadless Rule is an important mechanism for ensuring this conservation measure is put into practice. The United States Fish and Wildlife Service (USFWS) October 2024 Species Status Assessment for the Grizzly Bear in the Lower-48 States1 relies on the premise that the Roadless Rule is an inherent protection of the regulatory backdrop that will govern grizzly bear habitat conservation into the future, because the rule was upheld by the Tenth Circuit Court of Appeals in 2011 (Wyoming v USDA, 661 F.3s 1209 (10th Cir. 2011))2.

Grizzly bear populations require protected areas of 50,000 km2 in size to have a 90% chance of surviving3. The Demographic Monitoring Area for the GYE grizzly bear population (hereafter, DMA) is roughly 49,000 km2. To date, managers have presumed long-term protections of secure habitat across the geographic footprint of the DMA due to the built-in protections provided by key land designations such as Wilderness, Wilderness Study Areas, Recommended Wilderness, and Inventoried Roadless Areas (IRAs) provided by the 2001 Roadless Rule, as well as the habitat standards tied to the Recovery Zone incorporated via a 2006 GYE Forest Plan Amendment. If Forest Plans do not change, the preferred alternative could result in losing more than a quarter (26-27%) of the secure habitat acreage needed outside of the Recovery Zone for long-term GYE population viability. In a scenario where Forest Plan habitat standards within the Recovery Zone become less restrictive, loss of IRAs tied to the preferred alternative could lead to degradation of 17% of the overall protected area footprint needed to ensure a 90% probability of long-term population viability for GYE grizzly bears.

Functional connectivity between grizzly bear recovery ecosystems is critical to the long-term health of grizzly bear populations. Because the grizzly bear was listed as a threatened species in the contiguous lower 48 states under the U.S. Endangered Species Act (ESA) (40 Fed. Reg. 31,734 (July 28, 1975); GYC maintains that it is critical that grizzly bears be recovered and managed as a large, well-connected Northern Rockies meta-population. IRAs provide millions of acres of protection within modeled linkage areas for grizzly bears. Without IRAs the goal of achieving functional connectivity between grizzly bear recovery ecosystems is unlikely to come to fruition.

In short, the proposed action could preclude long-term viability of the GYE grizzly bear population. This pending policy rollback comes while the current Federal administration is striving to delist grizzly bears from the ESA based on plans that inherently rely on the existence of bedrock habitat protections such as IRAs.

Impacts to Elk and Other Migratory Ungulates

The GYE supports some of the most extensive and well-documented ungulate migrations in North America. Elk, mule deer, pronghorn, moose, and bison move seasonally across large landscapes and multiple jurisdictions to access winter and summer ranges and other seasonal resources. Research demonstrates that migratory ungulates depend on connected seasonal ranges, migration corridors, and stopover habitats, and that disruption or alteration of these movement systems can diminish the ecological benefits and functionality of migration (Sawyer et al. 2009; Middleton et al. 2013; Sawyer et al. 2013). Migration routes can also include constrained areas or bottlenecks where animals have fewer movement options and may be particularly vulnerable to habitat alteration and disturbance (Sawyer et al. 2013).

Winter range is similarly important. During winter, ungulates must conserve limited energy reserves, and increased movement or displacement can impose substantial energetic costs (Parker et al. 1984). Habitat conditions that influence nutrition and energy balance can, in turn, affect elk reproduction and survival (Cook et al. 2004). Maintaining secure winter habitat and connectivity between winter and other seasonal ranges is therefore important to sustaining migratory populations over the long term.

Road construction and associated human activity are particularly relevant to these species. Research has documented avoidance of roads by elk and reductions in effective habitat associated with roads and human access (Lyon 1979; Rowland et al. 2000). Research in forested landscapes has also documented displacement of elk in response to recreational activity, including motorized recreation (Wisdom et al. 2018). Roads and other landscape features can function as semi-permeable barriers to migratory ungulates, altering movement behavior and reducing use of important stopover habitat (Sawyer et al. 2013). Consequently, the effects of new roads and associated access may extend beyond their physical footprint through displacement, increased human activity, and reduced habitat security.

These effects warrant particular scrutiny in the GYE because migratory ungulates routinely move across national forests, national parks, other public lands, and private lands, encountering development, highways, fencing, recreation, and other constraints along the way. Additional roads, motorized access, timber harvest, and associated disturbance within current roadless lands could compound these existing pressures. Effects may be especially consequential where an IRA contains winter range, a migration bottleneck or stopover area, or secure habitat within an already constrained portion of a migration route.

Accordingly, the spatial analysis requested above should identify IRAs that overlap or contribute to known or modeled migration routes, stopover areas, bottlenecks, winter ranges, and other high-use habitats for elk, mule deer, pronghorn, moose, and bison, drawing upon available movement data and migration mapping from state wildlife agencies, federal agencies, researchers, and the U.S. Geological Survey. The final EIS should evaluate how the loss of Roadless Rule protections in these areas could affect displacement risk, habitat security, corridor functionality, and landscape permeability, including cumulatively with existing roads, development, recreation, fencing, highways, and other constraints along migration routes.

VI. The Scope of Potential ESA Effects Warrants Greater Scrutiny Before a Final Decision

The DEIS reports preliminary determinations that Alternative 2 'may affect and is likely to adversely affect' 327 Endangered Species Act-listed species and 71 designated critical habitats. It also reports 'may affect individuals or habitat' determinations for 3,490 Regional Forester Sensitive Species. DEIS at 25, 162-163.

Those findings underscore the ecological significance of the proposed action. GYC requests that the Forest Service complete consultation under Section 7 of the Endangered Species Act before issuing a final rule; incorporate the final Biological Assessments and consultation outcomes into the final EIS; disclose any conservation measures, reasonable and prudent measures, or other commitments relied upon; and explain how those measures affect the comparison among alternatives.

The final EIS should also more clearly analyze effects to Regional Forester Sensitive Species and, through government-to-government consultation, species and ecological resources identified by Tribal Nations as culturally important. These categories are not substitutes for ESA analysis, but they are important to understanding the broader ecological and cultural consequences of rescission. The final EIS should also avoid treating future project-level ESA consultation as a substitute for consultation on the rulemaking itself. The Roadless Rule rescission is the federal action under consideration, and its programmatic effects on listed species and critical habitat should be fully addressed at this stage.

VII. The DEIS Understates the Importance of Maintaining Intact Headwaters and Aquatic Systems for Fish, Wildlife, Climate Refugia, and Municipal Water Supply

Roadless lands in the Greater Yellowstone Ecosystem contain headwaters and cold-water systems that support native fish, downstream communities, recreation, agriculture, and wildlife. The Forest Service's own analysis explains that roads and timber harvest can increase erosion and sedimentation, alter hydrology and streamflow timing, increase stream temperatures, degrade water quality, and fragment aquatic habitat. DEIS at 111-118, 151-153. This poses an unacceptable risk to the nearly 10,400 miles of streams and rivers currently protected by the Roadless Rule in the Greater Yellowstone Ecosystem – representing nearly 46% of all streams contained on Forest Service-managed lands in the region. There is not a single municipality within the ecosystem that doesn’t rely on drinking water – directly or indirectly – from headwater systems that are partially or entirely protected by the Roadless Rule.

The DEIS notes that road construction and associated timber-sale facilities can account for a large share of sediment generated by timber activities, that best management practices reduce but do not eliminate impacts, and that landslides and debris flows are six to nine times more likely adjacent to forest roads in the research it cites. DEIS at 111-112. It also explains that roads can increase sediment loads, alter watershed hydrology and stream temperatures, degrade water quality, and increase barriers to aquatic movement. DEIS at 151-152. In the Western US, about 90% of people are served by public drinking water systems derived from NFS lands that include 71% of all IRAs in the nation (Liu et al., 2022). The Forest Service should not be in the business of knowingly polluting public drinking water supplies with additional road building that leads to sedimentation, chemical pollution, and increased costs for municipal water districts.

The Forest Service's own Watershed Condition Framework reinforces the importance of preventing degradation before restoration becomes necessary. The Framework states that national direction is, first and foremost, to protect high-value watersheds already in good condition, maintain watershed condition so that watersheds do not become threatened, and then improve impaired watersheds. USDA Forest Service, Watershed Condition Framework (2011), at 12. That prevention-first approach is consistent with the Multiple-Use Sustained-Yield Act, which calls for coordinated management of national-forest resources "without impairment of the productivity of the land" and defines sustained yield in the same terms. 16 U.S.C. § 531(a)-(b). The final EIS should explain how removing protections from intact headwaters is consistent with these longstanding management principles, particularly where new roads may create sediment, hydrologic, and maintenance impacts that later require restoration.

Rescinding the Roadless rule will have significant impacts on climate resilience, carbon storage, water resources, and aquatic ecosystems. Inventoried Roadless Areas (IRAs) encompass older, intact forest stands that serve as critical nationwide carbon sinks, absorbing heavy volumes of atmospheric carbon. Rescinding national protections to permit road construction and timber harvesting will reduce these active carbon sinks through tree removal and soil disturbance. Fragmenting these undisturbed landscapes destroys key biological corridors, restricting the ability of wildlife and plant species to migrate and adapt as temperatures rise. Removing tree canopy cover degrades cold-microclimate refugia, exposing temperature-sensitive species to severe edge effects like wind and invasive species invasion.

The proposed rescission also poses serious impacts to watershed health and regional fisheries. Undisturbed roadless watersheds rely on uncompacted soils and healthy root systems to retain moisture, recharge groundwater, and regulate streamflow. Constructing road networks compacts soil, accelerates surface runoff, and lowers water retention capacity during drought conditions, as well as increasing human access and the risk of wildfires. Increased road building, maintenance, and timber hauling will increase soil erosion and sedimentation into streams, degrading water quality, damaging fish spawning gravels, and disrupting aquatic food webs. The loss of shade provided by riparian tree cover will increase water temperatures and will place vulnerable cold-water fish populations like native trout and salmon under severe ecological stress.

The final EIS should identify affected IRAs that overlap public drinking-water source watersheds, 303(d)-listed waters, native trout strongholds, riparian conservation areas, eligible or designated Wild and Scenic River corridors, and climate-resilient cold-water habitat. It should analyze the cumulative vulnerability of these systems to additional roads and timber harvest rather than assuming that best management practices and later project design will fully address these risks.

VIII. Existing Forest Plans Are Not an Equivalent Substitute for the Roadless Rule

A central premise of the proposal is that local forest planning can provide place-based protection after rescission. The DEIS, however, documents substantial variation in the age and content of existing forest plans. It states that 108 of 126 current plans were developed or revised under the 1982 Planning Regulations, and that many plans revised after 2001 were completed during a period when the legal status of the Roadless Rule was uncertain and are therefore less likely to have incorporated IRA-specific direction. Only newer plans are more likely to identify IRAs as designated areas and include specific plan components. DEIS at 8.

The Roadless Rule currently operates as a consistent national conservation floor that supersedes less protective forest-plan provisions. Removing it would therefore have very different consequences from forest to forest, depending on the age and content of each plan. The final EIS should identify which forests currently provide protections equivalent to the Roadless Rule, which do not, and how many acres would experience a meaningful reduction in protection under Alternative 2.

This issue is especially important where forest-plan revisions are underway. The DEIS identifies the Bridger-Teton National Forest among forests currently revising their plans. DEIS at 35. Rescission of the Roadless Rule during an active plan revision could alter the regulatory baseline and affect the range of management choices being considered. The final EIS should disclose those consequences rather than relying on future planning as a generic mitigation mechanism.

IX. Tribal Consultation Must Be Completed and Tribal Consent Meaningfully Integrated Before a Final Decision

The USDA and Forest Service have a federal trust responsibility to tribes that includes upholding treaties. Several tribes whose Aboriginal homelands cover the Greater Yellowstone Ecosystem have off reservation hunting and gathering rights on "unoccupied lands" from the Ft. Bridger and Ft. Laramie Treaties. This right was recently upheld by Herrera v Wyoming, the landmark U.S. Supreme Court ruling affirming in 2019 that the Crow Tribe's 1868 federal treaty right to hunt on unoccupied federal lands was not automatically ended when Wyoming became a state. Inventoried Roadless Areas are unoccupied lands of national forests. If tribes have the right to hunt, fish, and gather, they have a stake in the conservation and stewardship of these resources. GYC requests that the Forest Service complete meaningful government-to-government tribal consultation and incorporate consent from tribes who have treaty rights and ancestral connections to Inventoried Roadless Areas as a respectful and necessary requirement for decision making.

GYC appreciates that the DEIS acknowledges the United States' unique nation-to-nation relationship with Tribal Nations, the federal trust responsibility, treaty-reserved rights, and the obligation for ongoing and meaningful government-to-government consultation. It identifies tribal interests in access, resource usability, sacred sites, clean water, biodiversity, subsistence, cultural practices, co-stewardship, Indigenous Knowledge, and intact landscapes. DEIS at 197-203.

The consultation record described in the DEIS appears incomplete at the draft stage. The Forest Service reports receiving 64 requests for consultation, with 29 consultations completed and five additional consultations scheduled, and states that consultation will continue throughout the rulemaking. It also states that a final Tribal Impact Summary Statement will not be included until the final rule. DEIS at 9. The DEIS further reports 'clear and consistent strong opposition' to rescission from tribes, with one exception of an Alaska Native Corporation, and concludes that Alternative 2 presents the greatest potential for adverse effects to tribal rights and interests. DEIS at 198, 203. It acknowledges that additional roads and timber harvest could alter access to treaty-reserved resources and sacred sites, fragment ancestral trails, increase unauthorized access and disturbance, degrade fish, game, plants and clean water, fragment wildlife corridors, and produce cumulative and intergenerational cultural impacts. DEIS at 201-203.

Against that record, it is not sufficient to defer meaningful resolution of tribal concerns to future site-specific consultation. The national rulemaking itself changes the management framework across ancestral homelands and areas containing treaty-protected and culturally important resources. USDA Departmental Regulation 1350-002 (Apr. 30, 2024) calls for timely, meaningful, and substantive government-to-government consultation on policies with tribal implications. The consultation process should occur early enough to influence the action, alternatives, and mitigation - not merely document tribal concerns after the agency has effectively selected a policy direction. The final EIS should also analyze the cumulative effect on Tribal rights of the rescission together with the Department's parallel NEPA, travel management, and emergency-designation actions, which the Draft EIS did not consider.

GYC therefore requests that USDA and the Forest Service: complete all requested government-to-government consultation before issuing the final EIS and final rule; disclose, to the extent consistent with confidentiality protections, how tribal input changed or informed the proposed action, alternatives, and mitigation; provide the Tribal Impact Summary Statement with or before the final EIS rather than only with the final rule; and explain how the agency has responded to tribal requests for a non-rescission alternative, tribal-specific management mechanisms, co-stewardship opportunities, and incorporation of Indigenous Knowledge.

The DEIS states that tribal letters and consultations proposed mechanisms allowing tribes to request management approaches for specific IRAs and a non-rescission alternative emphasizing cooperative agreements and Indigenous Knowledge, but the agency declined to analyze such an alternative in detail on the ground that co-stewardship is better addressed through local planning or project decisions. DEIS at 28-29. The final EIS should provide a more substantive explanation of why a tribal-informed national alternative is not reasonable, particularly when the agency simultaneously relies on tribal input as a central feature of its stated local-decision-making rationale. The DEIS should also analyze in detail at least one tribally requested alternative in a supplemental Draft EIS: a Traditional Homelands Conservation Rule, a co-stewardship alternative built on mutual concurrence, or a strengthened roadless alternative.

While GYC works to support the conservation and stewardship interests of tribes with living and ancestral connection to the the Greater Yellowstone Ecosystem, nothing in these comments is intended to speak for any Tribal Nation. GYC supports the sovereign right of each tribe to define its own interests, priorities, and preferred forms of engagement with the federal government.

X. The Proposed Expansion of Road-Building Opportunity Conflicts with the Forest Service's Existing Fiscal and Maintenance Constraints

The DEIS contains substantial evidence that additional roads would create fiscal liabilities that deserve greater weight in the decision. It estimates lower-48 road construction costs of roughly $80,000-$100,000 per mile for native-surface roads, with gravel and asphalt substantially more expensive. DEIS at 42.

The Forest Service estimates that maintaining its existing roads and bridges in good repair would require approximately $1.6 billion annually, while it received approximately $270 million in fiscal year 2023 - less than 20 percent of estimated need. Annual appropriations for road construction, improvement, and maintenance declined from $234 million in 2004 to $73 million in 2024, and the agency estimates a $6.9 billion deferred-maintenance backlog for passenger-car roads and bridges alone. DEIS at 42-44.

The DEIS nevertheless assumes that some new road construction and additional maintenance would result under the action alternatives and acknowledges that timber-sale or resource-extraction revenues would not be sufficient to cover all new road construction and maintenance costs. DEIS at 45. Before expanding opportunities to build roads into relatively intact areas, the final EIS should quantify expected fiscal effects, including maintenance, decommissioning, drainage, restoration, and long-term liability, and explain how additional roads are consistent with the agency's objective of maintaining the minimal road system needed for management.

GYC is also concerned about how a potential recission of the Roadless Rule will affect decommissioned roads that have been reclaimed to natural status. GYC has supported route closure and decommissioning in occupied grizzly bear habitat in the GYE in partnership with the Forest Service, which administers these programs and makes the associated decisions. GYC’s investment to date is approximately $600,000 over five years across three national forests in the GYE. GYC’s 2026–2031 Strategic Plan sets an outcome of more than 100,000 acres of secure habitat gained through road closures. Because the Grizzly Bear Conservation Strategy defines secure habitat as contiguous habitat of at least 10 acres located more than 500 meters from an open or gated motorized route, trail, or developed site (Conservation Strategy, ch. 3, p. 35 (2024)), each mile of route that is decommissioned rather than gated can contribute up to roughly 400 acres of secure habitat, where no other route lies within that distance. Investments of this kind were made in reliance on decisions the Forest Service reached through public processes and on habitat commitments in the Conservation Strategy and forest plans. Actions from the Forest Service to change course and use a Roadless Rule recission to revisit developing these closed roads will risk damaging good-faith relationships. As a close-working partner, GYC may be forced to seek legal or financial recourse.

XI. The Economic Analysis Should Fully Account for Recreation, Wildlife, and Non-Commodity Values

The DEIS acknowledges that long-term changes in aggregate recreation benefits under Alternative 2 are most likely to be losses because timber harvest and road construction are expected to degrade trail-based and dispersed recreation settings while producing relatively little net increase in road-based and developed-site recreation. DEIS at 224-225. It also acknowledges possible adverse effects on outfitters and guides where road construction or timber harvest degrades recreation quality, landscape conditions, or wildlife habitat.

These effects are especially relevant in the Greater Yellowstone Ecosystem, where hunting, fishing, wildlife viewing, outfitting, hiking, backcountry recreation, scenic quality, and intact landscapes are significant components of local economies and community identity. The National Park Service estimates that visitors to Yellowstone and Grand Teton National Parks alone spent approximately $1.52 billion in gateway communities in 2024, supporting 13,424 jobs and approximately $1.89 billion in economic output. Flyr et al. 2025, Table 4. More broadly, the Bureau of Economic Analysis identifies outdoor recreation as a significant component of state economies and provides state-level economic statistics for Montana, Idaho, and Wyoming. BEA, Outdoor Recreation Economic Statistics, U.S. and States, 2024 (2026). These figures do not measure the economic value of roadless lands themselves, but they demonstrate the importance of recreation and intact landscapes to the broader regional economy and the need for a balanced economic analysis. The final EIS should not frame the choice as conservation versus economic use; maintaining roadless character itself supports economic and social values that should be considered alongside commodity benefits.

The Forest Service should strengthen its regional analysis of recreation and wildlife-related economic benefits and compare those values with the expected incremental timber and other commodity benefits of rescission, including the public costs of road construction and maintenance.

The DEIS should also provide a more complete regional accounting of the economic tradeoffs associated with rescission. Where the agency quantifies potential timber-related revenues, it should provide forest- or unit-specific estimates for the national forests within the Greater Yellowstone Ecosystem and compare those incremental benefits with reasonably quantifiable recreation, tourism, water, wildlife, and public-infrastructure values and costs. NEPA specifically directs agencies to use methods that allow presently unquantified environmental amenities and values to receive appropriate consideration alongside economic and technical considerations. 42 U.S.C. § 4332(2)(B).

XII. Alternative 3 Carveouts Remove Protections Based on Broad Geographic Proxies That Require Greater Scrutiny

Alternative 3 would remove Roadless Rule protections from 31.7 million acres. These are lands and waters within the Healthy Forests Restoration Act of 2003 wildland-urban interface and within one-half mile of existing roads, among other categories. Only 13 million acres would retain current protection. Forest Service geospatial documentation describes the roaded-roadless criterion as a half-mile buffer around existing roads. Proximity to an existing road or inclusion within a mapped WUI, however, does not by itself establish that an IRA is suitable for new road construction or timber harvest, or that removing national protections is necessary to protect communities. The DEIS also does not provide adequate justification for determining a half-mile buffer around existing roads. In the United States, the average total road right-of-way (ROW)—the strip of land owned or controlled by a public entity for travel, drainage, and utilities —typically measures 66 feet (33 feet on each side of the road centerline) for standard rural and local roads. The Forest Service should start with this ROW measurement for focusing its array of management practices. The final EIS should identify the GYE acres that would lose protection under each Alternative 3 criterion and evaluate their actual vegetation, slope, access, wildlife, watershed, recreation, and wildfire-risk characteristics. It should also explain the basis for the half-mile road buffer and demonstrate how the mapped carveouts correspond to site-specific management needs rather than using proximity as a proxy for suitability.

XII. The Recission is Incompatible with Resource Conditions and Management Priorities of Specific IRAs in the Greater Yellowstone Ecosystem

The Proposed Roadless Rule states that "[u]nder the current Administration, the Department has refocused polices, programs, and resources on increasing rural economic development, decreasing Federal regulation and streamlining Federal Government services." (USDA, 2026, Proposed Roadless Rule, 4) Specifically, the document states the interests to advance the policy objectives of Executive Order 14225 Immediate Expansion of American Timber Production and Executive Order 14154, Unleashing American Energy (ibid, 4). This blanket Executive approach is not compatible with resource conditions and natural resource management priorities in the Greater Yellowstone Ecosystem. With few exceptions, Inventoried Roadless Areas in the GYE are too rugged for road building, too arid for sustainable timber production and commercial harvest, are composed of fragile soils and geologic bedrock that is sensitive to the lightest human impact and are quick to erode and lead to water quality impacts. Fish and wildlife values related to native trout, big game species, and endangered species like the grizzly bear and wolverine are a priority here. Much of the acreage is verdant but sensitive, alpine tundra, particularly in IRAs in the east and north of the ecosystem. Indigenous cultural resources are prolific. And oil, gas, and other mineral interests are very low or non-existent in availability and potential development.

Included below are a sampling of Inventoried Roadless Areas and their assets that are completely incompatible with the Executive Orders and current shortsighted direction and Preferred Alternative of the USDA and Forest Service.

• Hyalite- Porcupine-Buffalo Horn & Gallatin Fringe IRAs, Custer Gallatin National Forest - Big game (elk, mule deer, bighorn sheep) species. Grizzly bear. Alpine tundra. Solitude and primitive recreation opportunities are abundant.

• Bridger IRA, Custer Gallatin National Forest – Recreation is the priority human use. Steep terrain and erodible geology are poor for road building.

• Crazy Mountain IRA, Custer Gallatin National Forest - existing tribal and ancient Indigenous resources. Steep terrain and erodible geology are poor for road building. Recreation is the priority human use.

• Emigrant Peak and Chico Peak IRAs, Custer Gallatin National Forest - Steep terrain and erodible geology are poor for road building. Recreation is the priority human use. Grizzly bears. Elk.

• Dome Mountain IRA, Custer Gallatin National Forest - Steep terrain and erodible geology are poor for road building. Elk winter range and seasonal migratory paths.

• Big Horn Mountain, Vigilante, Cherry Lakes, Sheep Mountain, Freezeout Mountain, and Black Butte IRAs, Beaverhead-Deerlodge National Forest – all part of an extensive network of Gravelly Range IRAs that support a high density of grizzly bears and elk.

• Snowcrest Mountain IRA, Beaverhead-Deerlodge National Forest – steep terrain and erodible geology are poor for road building. Primitive recreation is the priority human use.

• Spread Creek – Gros Ventre River IRA, Bridger-Teton National Forest – some of the best middle elevation secure habitat for big game species and grizzly bears in the Greater Yellowstone Ecosystem.

• Salt River Range IRA, Bridger-Teton National Forest – Extremely steep terrain and erodible geology are poor for road building. Recreation is the priority human use.

• Telephone Draw IRA, Shoshone National Forest - existing tribal and ancient Indigenous resources. Big game (elk, mule deer, bighorn sheep) species. Grizzly bears. Alpine tundra. No Surface Occupancy with no potential oil and gas development.

• Francs Peak IRA, Shoshone National Forest – existing tribal and ancient Indigenous resources. Big game (elk, mule deer, bighorn sheep, pronghorn) species. High grizzly bear density. Alpine tundra. Unique opportunities for solitude and primitive recreation. No Surface Occupancy with no potential oil and gas development.

• Wood River IRA, Shoshone National Forest – existing tribal and ancient Indigenous resources. Big game (elk, mule deer, bighorn sheep, pronghorn) species. High grizzly bear density. Alpine tundra. Unique opportunities for solitude and primitive recreation. No Surface Occupancy with no potential oil and gas development.

• South Fork/Carter Mountain IRA, Shoshone National Forest – existing tribal and ancient Indigenous resources. Big game (elk, mule deer, bighorn sheep, pronghorn) species. High grizzly bear density. Alpine tundra. Unique opportunities for solitude and primitive recreation. No Surface Occupancy with no potential oil and gas development.

• South Beartooth Highway IRA, Shoshone National Forest – Almost exclusively alpine tundra. Recreation. No Surface Occupancy with no potential oil and gas development.

XII. Requested Action

The Greater Yellowstone Coalition urges the United States Department of Agriculture and the Forest Service to withdraw the proposed rescission and select Alternative 1 – No Action, keeping the 2001 Roadless Area Conservation Rule intact. GYC also encourages the Forest Service to clarify existing exceptions related to when forest supervisors and district rangers have the discretion to conduct temporary road building and timber management for the purposes of public health and safety, mitigating wildfire risk in the wildland-urban interface, and supporting fish and wildlife habitat improvement projects. GYC believes strongly that there is an opportunity to maintain the important water, wildlife, and cultural assets associated with Inventoried Roadless Areas as protected under the

Roadless Rule and simultaneously address public safety and infrastructure concerns related to wildfires and natural disasters. If the agency proceeds toward a final EIS, it should not issue a final rule until the deficiencies identified above are addressed. At minimum, the final EIS should:

• Evaluate an alternative that retains the 2001 Roadless Area Conservation Rule while providing narrowly tailored flexibility for demonstrated restoration, public-safety, and wildfire-risk needs;

• Clarify existing Roadless Rule exceptions and provide clear, consistent direction to local land managers on their implementation so that legitimate community-protection and restoration work can proceed without wholesale rescission;

• Provide more spatially explicit regional, state, and forest-level analysis of reasonably foreseeable road construction, timber harvest, wildlife-connectivity, secure habitat, watershed, recreation, and fiscal effects;

• Complete ESA consultation and incorporate final consultation outcomes into the final EIS;

• Complete requested government-to-government tribal consultation and demonstrate how consultation influenced the proposed action, alternatives, and mitigation before the final decision; seek consent from tribes on management actions that affect treaty lands and ancestral lands

• Analyze the consequences of relying on forest plans of widely varying age and protective strength as a substitute for the Roadless Rule;

• Quantify the net wildfire-management benefits of rescission and compare them with existing Roadless Rule flexibility, increased human-ignition risk, and targeted alternatives; and

• Quantify the water quality impacts from new road building and future road use due to sedimentation, siltation, thermal increases, new barriers, and/or chemical runoff from vehicles.

• Quantify the additional net cost of new road building on municipal water treatment systems who receive their water supply from Inventoried Roadless Areas.

• Fully account for road construction, maintenance, decommissioning, recreation, wildlife, watershed, and non-commodity economic costs and benefits.

Literature Cited

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Flyr, M., E. Stockmoe, C. Cullinane Thomas, L. Koontz, and C. Huber. 2025. 2024 National Park Visitor Spending Effects: Economic Contributions to Local Communities, States, and the Nation. Science Report NPS/SR-2025/353. National Park Service.

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Lyon, L.J. 1979. Habitat effectiveness for elk as influenced by roads and cover. Journal of Forestry 77(10):658–660.

Middleton, A.D., M.J. Kauffman, D.E. McWhirter, J.G. Cook, R.C. Cook, A.A. Nelson, M.D. Jimenez, and R.W. Klaver. 2013. Animal migration amid shifting patterns of phenology and predation: lessons from a Yellowstone elk herd. Ecology 94(6):1245–1256.

Parker, K.L., C.T. Robbins, and T.A. Hanley. 1984. Energy expenditures for locomotion by mule deer and elk. Journal of Wildlife Management 48(2):474–488.

Rowland, M.M., M.J. Wisdom, B.K. Johnson, and J.G. Kie. 2000. Elk distribution and modeling in relation to roads. Journal of Wildlife Management 64(3):672–684.

Sawyer, H., M.J. Kauffman, R.M. Nielson, and J.S. Horne. 2009. Identifying and prioritizing ungulate migration routes for landscape-level conservation. Ecological Applications 19(8):2016–2025.

Sawyer, H., M.J. Kauffman, A.D. Middleton, T.A. Morrison, R.M. Nielson, and T.B. Wyckoff. 2013. A framework for understanding semi-permeable barrier effects on migratory ungulates. Journal of Applied Ecology 50(1):68–78.

Wisdom, M.J., H.K. Preisler, L.M. Naylor, R.G. Anthony, B.K. Johnson, and M.M. Rowland. 2018. Elk responses to trail-based recreation on public forests. Forest Ecology and Management 411:223–233.

U.S. Department of Agriculture, Forest Service. 2011. Watershed Condition Framework: A Framework for Assessing and Tracking Changes to Watershed Condition. FS-977.