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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Decades spent living next to roadless areas in central Idaho, working as a whitewater guide on the Main Salmon and as a wilderness guard and river ranger on the Middle Fork Salmon, shaped who I am in ways I cannot fully account for. I hunted, fished, camped, hiked, and skied those drainages and carried the same habits into Colorado and Wyoming. Those experiences have been a huge positive influence on my life, and I want the same opportunity to exist for my son and grandchildren. The 2001 Roadless Area Conservation Rule is part of what keeps that opportunity intact. I oppose its rescission. I have commented on this matter before and received no response. I file this comment expecting the agency to engage with the specific points it raises and to answer them in the record it builds. The rule I guided on and worked in protects water that salmon need. Removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, and the affected area includes Essential Fish Habitat and critical habitats managed by NMFS. I have watched salmon in those rivers. I have worked that water. I have yet to see a plausible explanation of what we will do once the fisheries have been diminished. Beyond temperature, the DEIS itself acknowledges that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity," yet no projection of sediment delivery to downstream waters follows that finding. There are more than 7,000 municipal intakes sitting in watersheds that contain affected roadless areas. I ask that the agency calculate the projected sediment load reaching those intakes and place that calculation in the record before any final decision is made. One contamination pathway the DEIS does not appear to address at all is tire-derived pollutants. Compounds including 6PPD and 6PPD-quinone are shed from truck and car tires and migrate into waterways near roads. The resulting water toxicity has severe effects on fish and everything that depends on them. New roads built following rescission would extend the zone of exposure for salmon runs that are already under pressure. I ask the agency to address tire-derived contaminant loading as a distinct water quality effect in any final environmental review. The agency's own fire data undermines a central justification for the proposal. 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 same analysis concedes that road access could increase the number and frequency of wildfires. Despite that, the agency claims the rescission reduces wildfire hazard without quantifying the fires new road access would add. I ask that the agency project the expected increase in human-caused ignitions from new access and weigh it openly against whatever hazard-reduction claim it is advancing. The economic certification is also defective. 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. I was one of those outfitters operating on those rivers. The flexibility analysis reaches its no-impact conclusion by averaging a $9 million annual expenditure loss across every small firm in the sector nationally, rather than examining the guides and outfitters who actually hold permits in the affected areas. That method is not analysis; it is concealment. The agency must withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, the agency has affirmatively invited public comment but has not committed to weighing what it receives. 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 such a reliance interest. Decades of work, recreation, and expectation built on the rule's protections are real and they belong on the scale. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one, before it reaches a final conclusion. Sincerely, Steve Moore Captain Cook, HI

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Public lands should be accessible and sustainably maintained for everyone to enjoy, for current and future generations. I am a water resource engineer, and what is proposed here is not a close call: human activities undeniably impact water quality, and we cannot afford to further contaminate such a precious resource. Rescinding the 2001 Roadless Area Conservation Rule for the Trabuco roadless area in Cleveland National Forest, and for the 381 inventoried roadless areas totaling 4,389,760 acres across California, puts that resource directly at risk. Across the Pacific Southwest region alone, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own data shows that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. From a water resource engineering standpoint, the hydrology here is not ambiguous. Sediment loading of that magnitude, introduced into watersheds that are currently functioning, degrades drinking water quality, increases treatment costs, and creates impairment that is far easier to cause than to reverse. I ask that the agency respond on the record to the question of how it weighs the sediment productivity of new road construction against the drinking water function these watersheds currently provide to the communities they serve. On wildfire, 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." The proposal is justified in part on fuels management grounds, yet the agency's own findings indicate that road construction increases ignition risk rather than reducing it. The agency must explain why this proposal departs from its own prior findings on fire occurrence, and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission does not hold up on the agency's own numbers. The 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." Against that marginal production, the agency's Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, against recreation losses of at least $6.1 million a year, and a net present value that spans from a loss to a gain. The agency should reconcile the proposal with that analysis and explain how an action whose own accounting cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. That backlog is its own problem. The agency's record states: "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." The DEIS indicates that road mileage, deferred maintenance, and management costs are likely to increase under the proposal. Before this rule is finalized, the agency must name the funding source for new road construction and maintenance and state the projected change in that backlog. The Cost Benefit Analysis itself belongs on the docket, not in an agency file folder. The record contains this: "the net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million (-$70 to $152 million discounted at 7 percent) and uses maximum potential costs and benefits that do not account for uncertainty." The cost column in that analysis omits road construction estimated at $80,000 to $100,000 per mile, maintenance, and fuel treatment costs that the same document quantifies elsewhere. The upper bound assumes maximum potential harvest the analysis itself calls uncertain. The rule's claim that impacts could exceed $100 million appears with no arithmetic to support it. The agency must place the Cost Benefit Analysis on the docket, restate the net present value with its own quantified road and fuels costs included in the cost column, and show the arithmetic behind that claim. Sustainable management means leaving these areas in a condition that future generations can still use. Rescinding this rule, in the face of the agency's own data on sediment, fire ignition, fiscal shortfalls, and economic uncertainty, moves in the opposite direction.

I am a forest scientist who researches wildfire and heat/drought impacts on western US forests in OR, WA, CA, and CO. I am writing to strongly object to the proposed removal of the roadless rule, which purportedly is about reducing wildfire risk. This is FALSE - the rescinding of the roadless rule is really a timber and deregulation rule that mentions fire but is not about fire at all. Fire ignition data, including the USFS's 2001 finding that roads increase human-caused fire, rebut the rationale behind this proposed change. People start most fires in the American west. Increased public road access will raise the number and frequency of wildfires, without doubt. And USFS forest management plans already restrict harvest on 26.7 million acres regardless of the roadless rule. Additionally, the USFS cannot even maintain the forest roads it has already built, as it has a roughly $6.9 billion maintenance backlog on its roads! In addition, the proposed change makes NO economic sense and is wasteful to American taxpayers like myself. The USFS' own cost-benefit analysis shows a net present value range of negative $92 million to positive $199 million over fifteen years. The timber benefit of $9.9 to $22.0 million has to be weighed against $6.1 million in recreation losses and $5.3 to $11.5 million in forgone passive use. And there is a glaring arithmetic error: Table 1 lists minimum annual forgone benefits as $5.3 million while footnote 6 says costs include both the $6.1 million recreation loss and the $5.3 to $11.5 million passive use loss. The minimum should be $11.4 million! Critically, the biological assessment is a draft and incomplete. Even the draft finds this action is likely to negatively impact at least 300 listed species and some 45 designated critical habitats. The impacted species include grizzly bears, wolverines, gray wolves, Canada lynx, Mexican wolves, and fisher cats. Section 7 of the draft consultation is incomplete. A 30-day comment period based on on an incomplete biological assessment is not a lawful basis for a final rule. In conclusion, I am urging you to select Alternative 3, or better yet, no change to the Rule. The USFS' own analysis shows that limiting rescission to within a half mile of existing roads and the wildland-urban interface captures roughly 80% of the timber benefit on a fraction of the footprint — this is exactly where the fire prevention rationale is strongest! Why is the propsoal not focused on this if it's about fire? Also, please consider alternatives that multiple tribes requested that the agency did not analyze. Thank you.