Read the comments.

I have 17 years of land management experience with the US Forest Service and 21 years with the US Fish and Wildlife Service. I understand first-hand how these lands are critical to water and watershed protection, wildlife and fisheries habitat, reduced risk of wildfires, and world-class recreation. I live adjacent to the San Juan National Forest in southwest CO, and allowing impacts to these lands would be devastating. A study done in Colorado supports all my concerns. I include it here as part of my comments. https://roadless.org/resources/colorado-wildlands-report.pdf Rescinding the Roadless Area Conservation Rule (the Rule) threatens all of these benefits and gives control of these roadless public lands to greedy extractive industries and administration cronies. Road construction is not one threat — it is the enabling condition for most of the major threats that imperiled species and ecosystems face on National Forest lands. The Inventoried Roadless Areas exist in their current ecological condition because roads were never built. Rescinding the Roadless Rule activates a cascade of harm documented by NatureServe, the IUCN, and the U.S. Fish & Wildlife Service. I am also concerned with NEPA adequacy concerning this proposal, including the cumulative-effects analysis, range of alternatives, and other procedural requirements that a Draft EIS must satisfy. I will highlight my concern with a narrowly drawn purpose and need statement that forecloses meaningful alternative analysis. The Purpose and Need statement frames the rescission's justification exclusively around the Department's stated belief that "increased management flexibility in the administration of these lands is needed to better meet the multiple-use mission" (Purpose and Need for Action, pp. 18-19), without articulating any criteria against which intermediate alternatives—short of full nationwide rescission—could be meaningfully measured. This framing risks predetermining the outcome by defining the need in terms that only wholesale rescission can satisfy, foreclosing genuine consideration of a reasonable range of alternatives as NEPA requires under 42 U.S.C. § 4332(2)(C). As the Seventh Circuit recognized in the persuasive, out-of-circuit decision Simmons v. U.S. Army Corps of Engineers, 120 F.3d 664 (7th Cir. 1997), a narrowly drawn purpose and need statement that forecloses a reasonable range of alternatives violates NEPA's core mandate. I ask the agency to broaden its purpose and need framing with articulable criteria that permit genuine evaluation of intermediate management-flexibility options. The Purpose and Need section frames rescission almost entirely around administrative flexibility while giving only passing acknowledgment to the 2001 Rule's protective function. The DEIS itself states that the 2001 Rule was "intended to provide lasting protection for inventoried roadless areas," then pivots directly to the assertion that "increased management flexibility... is needed to better meet the multiple-use mission" (Purpose and Need for Action, pp. 18-19), without weighing that flexibility against the ecological values the Rule was designed to protect. Independent research found that 57% of wildlife species of conservation concern have suitable habitat in inventoried roadless areas, and that these areas often protect watersheds supplying drinking water to hundreds of thousands of people. The document does not address whether the agency considered this evidence or why it was rejected. NEPA requires forthright disclosure of trade-offs under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989) and 42 U.S.C. § 4332(2)(C). I request a revised, balanced Purpose and Need section addressing these values. I implore you to stop this action of rescinding the Roadless Area Conservation Rule. Nancy McGarigal Dolores, CO