Read the comments.

I submitted comments to the proposed rule in Sept 2025. Attached below. Consider these integral to my current comments. I strongly oppose recission of the 2001 Roadless Rule. I served on the roadless rule Content Analysis Team (CAET) in 2000, we read and synthesized all comments. Sentiment strongly favored protecting roadless areas and benefits they provide: clean water, biological diversity, wildlife habitat, forest health, and recreation. Climate change and population growth have increased support for roadless areas. I worked on the WMPZ Forest Plan Revision Team for forests in Western Montana; Flathead, Lolo, and Bitterroot. Despite efforts and substantial expense by American taxpayers, these were shelved due to a national lawsuit. Courts ruled the 2005 planning rule was inconsistent with the National Forest Management Act. The Flathead National Forest completed its forest plan revision in 2018 under the 2012 planning rule. My September 2025 comments must be considered in conjunction with my current comment for 53828 Federal Register/Vol. 91, No. 160/Thursday, August 20, 2026/Proposed Rules, which states, “As resource conditions and national policy have evolved, the Department has determined that a single, national blanket approach to the management of inventoried roadless areas taken in the 2001 Roadless Rule constrains responsible officials from exercising the timely, place-based discretion needed to meet the Forest Service’s multiple-use mission.” NOTE: While the 2001 roadless rule constrains officials from exercising their absolute place-based discretion, it does not follow such discretion is needed to meet the Forest Service’s multiple-use mission. On the contrary, NFMA was driven by management skewed to commodity production over multiple use values: watershed, wildlife, wildlands, recreation. Conditions on the Bitterroot amd the Monongahela national forest were evidence a more balanced approach was needed, resulting in NFMA. “In addition, evolving national priorities and changed conditions have required more active management approaches. The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which in turn has contributed to challenges in addressing forest health concerns.” NOTE: See pg 8 from my 2025 comments for a research being done. There are volumes that dispel lack of active management as a driver of forest health concerns. On the contrary, there is evidence forest management itself fosters such concerns. “This proposed rescission is intended to return primary authority for determining the appropriate management of inventoried roadless areas at the local level to the land management planning process mandated by the National Forest Management Act of 1976 ……The National Forest Management Act establishes the requirement for the Forest Service to develop land management plans, including direction in 16 U.S.C. 1604(a) and (b) for interdisciplinary planning and consideration of landscape-level conditions. These statutory requirements are implemented through the Agency’s land management planning framework, which require consideration of the plan area in the context of the broader landscape and requires that each plan reflects the unit’s expected distinct roles and contributions to the local area, region, and Nation. “ NOTE: Interdisciplinary planning and consideration of landscape-level conditions was done on the Flathead NF and ongoing revision on the Lolo NF. Refer to my Sept 2025 comment using Flathead as an example. Of 500,000 roadless acres, fewer than 200,000 remained. The rest were assigned management areas based on conditions and public input. Decision-makers balanced conflicting uses and devised management area prescription for roadless areas. “At the same time, this planning approach allows for place- based, collaborative decisionmaking that is responsive to specific on-the- ground resource conditions, rather than a ‘‘one-size-fits-all’’ national mandate. While national-level considerations are important, land management planning efforts by local decisionmakers at the national forest or regional scale are best positioned to make decisions about inventoried roadless areas because they understand the unique ecological, economic, and social needs of their communities.” Note: Yes, this is being done for revisions under the 2012 planning rule. Ironically, the Roadless Rule Recission is itself a blanket one-size-fits-all mandate that the rule dispesl. I requested the DEIS disclose forests that have done plan revisions, those in the process, and those not started. Only those that have not started could be subject to the recission. Those completed or undergoing revisions have engaged in place-based, collaborative decision-making responsive to on-the-ground conditions. The DEIS fails to respond to my request.

I am writing in favor of keeping the 2001 Roadless Area Conservation Rule as-is and in opposition to this proposed change that would rescind the 2001 Roadless Area Conservation Rule. Keeping roadless areas of our national forests is vital for long-term resource security, safety, and conservation. Rescinding the Roadless Rule and increasing the number and total length of roads will endanger our national forests by increasing the risk of wildfire and introduction of invasive species. Roads can increase the frequency of wildfires (eg, Narayanaraj and Wimberly 2012, Bowring et al 2024) - and even though fragmentation may reduce burn area, forest fragmentation is harmful to plants and animals in many ways and should not be viewed as an overall benefit or solution for wildfires. Similarly, roads (ie, human mediated travel) are a known dispersal pathway for invasive species (eg, Mortensen et al 2009, Ladin et al 2023, Solano et al 2021, Haubrock et al. 2026); many pest insects threaten our forests and to speed their spread into currently roadless areas could cause irreparable harm and economic loss (Lovett et al 2016). The National Forest Management Act requires that plans shall assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness (16 U.S.C. 1604(e)(1)). Rescinding the roadless rule will be harmful to fish and wildlife by increasing forest fragmentation, destroying habitat, increasing soil disturbance and run-off into waterways, and increasing the likelihood of human-wildlife conflicts (Croke and Hairsine 2006, Robinson et al 2010, Boston 2016). These conflicts will be great in magnitude if the roads lead to more timber production and mining. Increased timber production and mining is harmful to fish and wildlife. Furthermore, increasing roads and areas where natural resources are extracted will reduce access for recreation and have a negative economic impact on the tourism industry. The Forest Service's own analysis shows economic losses from reduced tourism and recreation caused by rescinding the Roadless Rule. Our National Forests should remain intact and roadless so Americans can enjoy them now and for centuries in the future. Short-term gains from resource extraction are not more important that the long-term integrity and preservation of our natural areas and resources for all Americans and future Americans to enjoy. Finally The rule states that "local decision making would remain subject to the substantive requirements of the Endangered Species Act". However, current changes to the Endangered Species Act means that any roads, timber harvest, of mining that removes habitat and other resources necessary for endangered species to survive would not be a violation of the Endangered Species Act. Therefore, endangered species are at highest risk by rescinding the Roadless Rule. Species cannot survive if their habitats are destroyed, degraded, and fragmented. I urge the USDA to protect our natural resources and do NOT rescind the Roadless Rule. Narayanaraj and Wimberly 2012 - https://doi.org/10.1016/j.apgeog.2011.09.004 Bowring et al 2024 - https://doi.org/10.1038/s41467-024-53460-6 Mortensen et al. 2009 - https://doi.org/10.1614/IPSM-08-125.1 Ladin et al. 2023- https://doi.org/10.1038/s41598-022-25989-3 Solano et al. 2021 - doi: 10.1093/jee/toaa278 Haubrock et al 2026 - doi: 10.1002/brv.70121 Lovett et al 2016 - https://esajournals.onlinelibrary.wiley.com/doi/pdf/10.1890/15-1176 Croke and Hairsine 2006 - https://cdnsciencepub.com/doi/10.1139/a05-016 Robinson et al 2010 - doi:10.1139/A10-002 Boston 2016 - DOI 10.1007/s40725-016-0044-x

This comment expresses strong opposition to the proposed rule, 91 FR 53827, since it is not aligned with the US Forest Services' mission and responsibility to citizens of the United States of America, as explained below, and I express my strong disagreement with the proposed rule and the process used to develop it. Adoption of the proposed rule would be neglect of the Forest Services' duty to manage National Forest for many uses in for the benefit of the citizens of the United States of America. Scientific evidence shows ROADLESS AREAS preserve clean water, clean air, species of importance, the health of areas with roads, and the value of forest products. The proposed rule is contrary to 16 USC 1604(a) and (b) regarding development of landscape-level management plans. The economic impacts described in the proposed rule are vague and incomplete. The proposed rule will increase bureaucracy, cost and regulatory burden on citizens and private enterprise by requiring hundreds of different local land management plans and is not in the interest of the people of The United States of America. Roadless areas prevent clear cutting instead of selective logging which increases fire risk. Roads are not required for selective logging and road construction money, and the cost of construction and maintenance is not calculated directly in the "Timber" section of the proposed rule. Elimination of the current rules governing roadless areas, under a single national blanket, will promote a return to pre-2001 abuses of National Forest in which large areas were clear-cut allowing densely forested areas to grow back with increased fire risk.Furthermore, contrary to the proposed rule's statement that "rescinding the 2001 Roadless Rule would increase opportunities for hazardous fuel treatments," it would provide for greater likelihood of human-caused wildfire ignition and growth of the wildland-urban interface. The Forest Service needs funding to restore the health of areas that have been used for commercial logging using selective logging and other best practices to assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, timber, watershed, wildlife and fish, and wilderness. The proposed rule jeopardizes all of the above products and services by reducing prices of forest products, polluting water sources, eliminating critical habit for wildlife and fish, eliminating wilderness quality land, and reducing opportunities for non-motorized recreation. In 2001, the current ROADLESS AREAS RULE (66 FR 3244) was adopted after extensive study and agreement by stakeholders to balance the use of National Forests for human and environmental health and commerce. The proposed rule will negatively impact the health of citizens of the United States, public infrastructure, and the value of commerce. Firstly, the proposed rule would eliminate protection for ROADLESS AREAS in National Forests and therefore endanger human health and well-being by polluting water sources, spreading invasive species, and emitting greenhouse gases and other pollutants that promote climate change and its negative impacts on the health, wealth and happiness of citizens of the US, including wildfire. Secondly, the proposed rule is not a result of scientifically based study nor of rigorous cost-benefit analysis that accounts for the costs of road construction and maintenance, impacts of water pollution, and reduction in price of forest products due to increase in supply subsidized by the government in competition with the free market price. In addition to the reasons given above, since, the proposed rule is not based on sound environmental or economic analysis implementation of this rule is not in the interest of the people of the United States of America and constitutes dereliction of responsibility of the US Forest Service and its administrators.

I am writing in support of keeping the Roadless Area Conservation Rule set by the USDA Forest Service in place. As stated on the official regulations.gov comment page, the Roadless Rule has been upheld by federal appeals courts. The rule was created with widespread bipartisan support in 2001 with the views and service for the American people in mind. This attempt at rescission is being framed as being beneficial for the American Public, but opening up the Inventoried Roadless Areas would actually harm the American public in multiple ways. As stated “The National Forest Management Act requires that plans shall assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness (16 U.S.C. 1604(e)(1)). The National Forest Management Act establishes the requirement for the Forest Service to develop land management plans, including direction in 16 U.S.C. 1604(a) and (b) for interdisciplinary planning and consideration of landscape-level conditions.” The Roadless Rule rescission would likely make it more difficult for USFS to manage these properties for their multi-use designations. Roads already exist throughout the vast majority of USFS lands due to these areas being reasonably accessible and able to create timber profits. Opening more areas to timber extraction goes against the multi-use directive by limiting outdoor recreation, watershed, and wildlife considerations as well as has negative economic impacts. Rural areas increasingly depend on our National Forests for ecotourism including hunting, fishing, and recreation with visitors adding significant economic provisions to these local economies. By opening up these areas to timber extraction, the USFS removes a long term and sustainable source of economic power for these communities in favor of short term gains. Roadless Areas are also providing significant uncalculated water quality benefits. Many Roadless Areas contain the headwaters of tributaries that supply fresh drinking water to millions of Americans. Opening up Roadless Areas will negatively impact water quality, putting an additional financial strain on municipalities treating the water and putting Americans at risk. The rescission attempt also states that this would assist the USFS with addressing wildfire issues. This is a complex topic, but can be simplified in many ways. 1. Researchers are finding no significant difference in Roadless Areas burned compared to forests near roads. 2. Roads can often act as the ignition source for destructive forest fires, building more roads would actually have the opposite intended effect of exacerbating wildfires in our public lands. 3. Most of the American landscape is ecologically and evolutionarily adapted to fire. Since Roadless Areas are roadless, and have a reduced Wildland Urban Interface, our wildfire fighting resources would be better spent focused on infrastructure rather than the back country. Timber specialists and researchers have also found that the expense of extracting timber from these areas have limited if not net losses for the American taxpayer; contrary to what the stated goal of the rescission is. The argument that roads would likely be temporary and that logging operations could provide an economic boon for the Forest Service is optimistic at best and dishonest at worst. The rescission document itself states “However, given the small number of operable areas for timber harvest in roadless areas and the large number of variables that may occur, it is difficult to predict the potential impact rule rescission may have on timber harvest.” In all, the Roadless Rule was put in place with wide support and with good reason in 2001. The reasons provided by the USFS to rescind the rule in 2026 fall short of reasonable and sound logic and is an incredibly unpopular decision. The USFS should listen to the American public who deeply value our public lands and leave the Roadless Rule in place. People of all walks of life and backgrounds supported this measure to leave currently undeveloped forest service land, roadless and undeveloped.

America is known for being the "great melting pot." The idea that American greatness comes from diversity is one that is core to this country, and I believe the same holds true of our natural environment. From the Great Plains to the redwood forests of California, or even the Sonoran desert which I call home, the breadth of natural beauty found in this country is beyond compare. This is why I find it so alarming that we are allowing our natural resources to be "exploit[ed]," as it is used in the second paragraph of Executive Order 14225, for short term gain. These changes will affect habitats for endangered species, and having their loss be described as merely a part of "[l]osses in economic benefit to recreationists" raises concerns. Assurances that the National Forest Management Act requires "sustained yield" of wildlife are hardly comforting due to recent developments. (16 U.S.C. 1604(e)(1)). Eleven days ago as of the time of writing, the definition of "harm" in the Endangered Species Act was rescinded to remove deaths caused by environmental impact. (I left my bluebook at home so you will have to deal with me citing the docket number, my apologies.) Docket (FWS-HQ-ES-2025-0034). (I left my bluebook at home so you will have to deal with me citing the docket number, my apologies.) Bald eagles, the symbol of our great Nation, will have their numbers hurt by executive demands to "exploit" their habitat, and the image of the symbol of our country quite literally dying is hard to balance by making progress towards the goal of reducing our reliance on the importing of foreign lumber. I acknowledge that there is still plenty of natural land, and that this change does not signal the death of all natural life, but the erosion of protections and habitats are alarming. Once this land has been "touched," that cannot be undone. I merely hope that we do not prevent future generations from experiencing the incomparable beauty this country has to offer so that we may increase short-term profits.

US Forest Service docket number FS-2025-0001 or RIN 0596-AD66 I am writing to express my strong oppoisiton to the proposed rescission of the 2001 Roadless Area Conservation Rule. Federal lands belong to ALL of the citizens of the United States, NOT to local entities or corporations. Federal management allows overall ecosystem management, tracking and managing biodiversity, watershed management that crosses multiple jurisdictions, and fire mitigation and control, which seems to be the reason given for this administration’s desire to give away the sanctity of our Federal lands, and roadless areas in particular. That is a thin veil to actually allow further development and resource extraction by special interest groups/cronies. Forest managers can already request special dispensation for building new roads in our National Forests. The review process is lengthy on purpose, to allow for public comment, to ensure biological, geological, archeological and other data to be analyzed fully. The rescission of the Roadless Rule goes against the multiple use policy of the US Forest Service by putting timber harvesting over every other benefit of the forest ecosystem. The National Forest Management Act requires that plans assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness (16 U.S.C. 1604(e)(1)). The National Forest Management Act establishes the requirement for the Forest Service to develop land management plans, including direction in 16 U.S.C. 1604(a) and (b) for interdisciplinary planning and consideration of landscape-level conditions. These statutory requirements are implemented through the Agency's land management planning framework, which require consideration of the plan area in the context of the broader landscape and requires that each plan reflects the unit's expected distinct roles and contributions to the local area, region, and Nation. The land management planning framework ensures each land management plan addresses similar conservation objectives as the 2001 Roadless Rule was intended to address, such as ecological integrity (including air, soil, and water), sources of public drinking water, diversity of plant and animal communities (including federally listed threatened and endangered species), sustainable recreation, scenic character, and protection of cultural and historic resources. Eliminating the Roadless Rule will undercut the integrity of the NFMA and damage our national forests. Leave the roadless rule in place!

Dear U.S. Service Chief Tom Schulz, Thank you for the opportunity to comment on the proposed recission of the 2001 Roadless Area Conservation Rule. I have reviewed the information posted in the Federal Register docket number FS-2025-0001 / RIN 0596-AD66 and the accompanying Draft EIS. After reviewing those materials, I urge you to choose Alternative 1 outlined in the Draft EIS, which will maintain the current 2001 Roadless Area Conservation Rule. As stated in the Federal Register’s rational for the proposal (Federal Register p. 53828), the National Forest Management Act (NFMA) of 1976 requires that forest plans “shall assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness (16 U.S.C. 1604(e)(1)).” Those uses are co-equal: Extractive uses do not have priority. The current inventoried roadless areas (IRAs) in our National Forest System are crucial for maintaining the wilderness, watershed, fish and wildlife values of our forests. Outdoor recreation, which can and does include hunting, fishing, hiking and camping, are compatible with maintaining the IRAs. The draft EIS states on p. 29 that numerous activities are allowed in IRAs, if not restricted by land management plans or other regulations. “These activities include, but are not limited to, the following: Maintaining existing roads; Constructing or maintaining motorized and non-motorized trails; Engaging in hunting, fishing, hiking, camping, and other recreational uses; Using a motorized vehicle, such as an off-highway vehicle, on a trail open to motorized use; Riding a bike on a trail open to mechanized use; Implementing prescribed burning; and Grazing livestock.” Roadless areas protect the crucial stream and river headwaters upon which many Americans and fish and wildlife depend. Roads will harm those streams and headwaters by increasing soil erosion, runoff, and sedimentation, thereby degrading fish and wildlife habitat and compromising water quality for humans and for fish and wildlife. The National Forest System is also charged with maintaining wilderness, which by definition requires roadless areas. Roadless areas provide crucial, unfragmented habitat and corridors for many wildlife species, including large game animals and threatened and endangered species. Roads also are conduits for invasive species, which threaten all the values that our forests are supposed to maintain: Range, timber, watershed, wildlife and fish, and also wilderness. Invasive grasses such as cheatgrass and buffelgrass, invasive shrubs and also trees increase wildfire risks. Our native plants and animals don’t always have adequate defenses against invasive insects and other animals. IRAs are necessary to make sure that our forests are not overrun and degraded by invasive species. With regard to fire on U.S. National Forests, p. 89 of the Draft EIS states, “ignition density is approximately four times greater on other NFS lands compared to the potentially affected IRAs and wilderness.” Fire is a natural process in North American forests, but the number of human-caused ignitions in our forests is not. Note that the current roadless rule does not bar all roads from IRAs. Table 1 of the draft EIS lists all the circumstances under which a road may be appropriate. In addition, as detailed in the draft EIS on p. 14, determination of exceptions are under local control – the regional forester. Again, I urge you to choose Alternative 1 outlined in the Draft EIS. Most of our National Forest lands are not inventoried roadless areas. Maintaining the 2001 Roadless Area Conservation Rule and the Forest’s IRAs will protect the legally mandated purposes of our National Forest System: outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness. Sincerely yours, Mari Jensen M.S. Renewable Natural Resources Studies University of Arizona

US Forest Service docket number FS-2025-0001 or RIN 0596-AD66 I strongly object to the U.S. Department of Agriculture’s proposed rescission of the 2001 Roadless Area Conservation Rule (2001 Roadless Rule). Our Federal lands need to be managed at the Federal level to avoid local politics that typically involves local citizens wanting easier access and more opportunities for exploitation of the natural resources. Federal lands belong to ALL of the citizens of the United States, NOT to local entities or corporations. By maintaining a Federal lens on management of ALL of our public lands, a bigger picture outlook can be maintained. A few of the many examples of this includes widespread ecosystem management, tracking and managing biodiversity, watershed management that crosses multiple jurisdictions, and yes, even fire mitigation and control, which seems to be the reason given for this administration’s desire to give away the sanctity of our Federal lands, and roadless areas in particular. Systems are already in place to allow forest managers to request special dispensation for building new roads in our National Forests. The review process is lengthy on purpose, to allow for public comment, to ensure biological, geological, archeological and other data to be analyzed fully. The rescission of the Roadless Rule goes against the multiple use policy of the US Forest Service by putting timber harvesting over every other benefit of the forest ecosystem. The National Forest Management Act requires that plans shall assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness (16 U.S.C. 1604(e)(1)). The National Forest Management Act establishes the requirement for the Forest Service to develop land management plans, including direction in 16 U.S.C. 1604(a) and (b) for interdisciplinary planning and consideration of landscape-level conditions. These statutory requirements are implemented through the Agency's land management planning framework, which require consideration of the plan area in the context of the broader landscape and requires that each plan reflects the unit's expected distinct roles and contributions to the local area, region, and Nation. The land management planning framework ensures each land management plan addresses similar conservation objectives as the 2001 Roadless Rule was intended to address, such as ecological integrity (including air, soil, and water), sources of public drinking water, diversity of plant and animal communities (including federally listed threatened and endangered species), sustainable recreation, scenic character, and protection of cultural and historic resources. Eliminating the Roadless Rule will undercut the integrity of the NFMA. Hands OFF our public lands!

The 2001 Roadless Rule, the limited number of roads within inventoried roadless areas and the inability to reconstruct or build new roads to provide the needed access further limit management flexibility. Taken together, the prohibitions have removed important management tools for key areas where there are needs or opportunities to address overgrown and fuel-loaded national forests. This proposed rescission is intended to return primary authority for determining the appropriate management of inventoried roadless areas at the local level to the land management planning process mandated by the National Forest Management Act of 1976 (16 U.S.C. 1600 et seq. ). The National Forest Management Act requires that plans shall assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness (16 U.S.C. 1604(e)(1)). The National Forest Management Act establishes the requirement for the Forest Service to develop land management plans, including direction in 16 U.S.C. 1604(a) and (b) for interdisciplinary planning and consideration of landscape-level conditions. These statutory requirements are implemented through the Agency's land management planning framework, which require consideration of the plan area in the context of the broader landscape and requires that each plan reflects the unit's expected distinct roles and contributions to the local area, region, and Nation. The land management planning framework ensures each land management plan addresses similar conservation objectives as the 2001 Roadless Rule was intended to address, such as ecological integrity (including air, soil, and water), sources of public drinking water, diversity of plant and animal communities (including federally listed threatened and endangered species), sustainable recreation, scenic character, and protection of cultural and historic resources. At the same time, this planning approach allows for place-based, collaborative decisionmaking that is responsive to specific on-the-ground resource conditions, rather than a “one-size-fits-all” national mandate. While national-level considerations are important, land management planning efforts by local decisionmakers at the national forest or regional scale are best positioned to make decisions about inventoried roadless areas because they understand the unique ecological, economic, and social needs of their communities. In 2001, USDA and the Forest Service asserted that a national prohibition was the best means to reduce conflict and potential for incremental impacts to the ecological and social values of these areas. Since then, conditions across National Forest System lands have changed substantially, especially in the Western United States where many inventoried roadless areas are located, with increasing drought, extreme temperatures, wildfire frequency and severity, and insect and disease outbreaks. Alongside these landscape changes, the Agency's land management planning framework has become more adaptive, science-based, efficient, and effective. These changes, combined with evolving Department priorities for active forest management and deregulation, diminish the basis for a national prohibition. The proposed rule would return land management decisionmaking for inventoried roadless areas to local Forest Service officials—giving them the flexibility to address conservation and resource issues informed by input from stakeholders, communities, and state, local, and tribal governments. Local decisionmaking would remain subject to the substantive requirements of the Endangered Species Act, National Forest Management Act, and other related laws and regulations.

I oppose rescission of the 2001 Roadless Area Conservation Rule (2001 Roadless Rule). The National Forest Management Act requires that land management plans “assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness (16 U.S.C. 1604(e)(1)).” This rescission prioritizes timber production over all other uses and is blatantly stated in Executive Order 14225, "Immediate Expansion of American Timber Production." This is the opposite of returning forest management to "local control." Recreation: Your own ‘Summary of Potential Impacts’ states that, “expansion could increase road-based recreation and accessibility improvements but would result in tradeoffs with opportunities for quiet, remote and self-reliant recreation and may increase user conflicts and result in lost economic benefits…an estimated $6.1 million annually.” Timber: Your own ‘Summary of Potential Impacts’ states that while timber production could result in a “5 to 10 percent increase in total annual National Forest System sawtimber harvest,” that “any efficiency gains are expected to be incremental and limited by road costs, maintenance funding gaps, and the $6.9 billion deferred maintenance backlog for roads and bridges.” Wildfire: Contrary to the ‘Summary of Potential Impacts’ on roads increasing access and therefore reducing wildfire risk, research indicates that wildfires are more common in areas with roads. According to a 2017 study published in the Proceedings for the National Academy of Sciences, “Human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, dominated an area seven times greater than that affected by lightning fires, and were responsible for nearly half of all area burned. National and regional policy efforts to mitigate wildfire-related hazards would benefit from focusing on reducing the human expansion of the fire niche.” This stands in contrast to the assertion that wildfire risk in national forests is due mainly to “limited mechanical thinning options and [lack of] some fire control tactics in inventoried roadless areas.” Forest Ecosystem management: Roadless areas are less prone to the expansion of invasive species. A 2020 study by the Forest Service's Rocky Mountain Research Station found non-native plants are twice as prevalent within 500 feet of roads compared to areas farther away. Wildlife management: Roadless areas provide important cold-water fish and big game habitat, support many plant and animal species, and protect migration corridors for elk, mule deer, and pronghorn antelope. They also offer quality hunting and fishing opportunities. This rescission works against the very objectives stated in the “Rationale for the Proposal.” It is absolutely true that, “Conditions across National Forest System lands have changed substantially, especially in the Western United States where many inventoried roadless areas are located, with increasing drought, extreme temperatures, wildfire frequency and severity, and insect and disease outbreaks.” However, rescission of the Roadless Rule as a means of addressing these changes is the opposite of “science-based, efficient, and effective,” and will exacerbate the very conditions it is proposing to solve.