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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The rescission of the Roadless Area Conservation Rule is, as far as I can tell, purely about removing regulatory burden. It does not promise road development. It does not promise logging. It simply strips away protection from some of the last remaining old growth forestland in the world, for no reason the agency has made plain. This is old growth. It takes centuries to even approach that designation. Reforestation efforts across the world today pale in comparison to what true old growth forest represents. If roads go in and that land is destroyed, nothing like it may never be able to grace the earth again. The Forest Service held more than 600 public meetings and took 1.6 million public comments to put this rule in place. To undo something so substantial without a single comparable public process is, to me, a mistake. I ask that the agency explain what process it believes substitutes for that record of public participation, and why rescission of a rule built on 1.6 million comments requires none of its own. On water, the agency's own data shows that 24 million Americans drink water that originates in these roadless areas. Roads are known to cause contamination in the areas where they are built. The agency's own analysis confirms this directly, finding that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Rescinding this rule opens those watersheds to exactly that kind of harm, affecting the drinking water of millions of Americans with little to no real benefit. I ask the agency to explain on the record what specific, quantified benefit justifies that risk to public water supplies. On wildfire, the proposal invokes forest health and fuels management as justification for rescission. The agency's own record says the opposite: "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 offers no reconciliation with that finding. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. On the state-by-state approach, the agency has already traveled this road and lost. The record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." Courts rejected that state-by-state substitute before. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified when the agency last tried to replace the national rule with state petitions. On statutory authority, the proposal argues the 2001 rule exceeded what Congress authorized. A federal appellate court already answered that question: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit held the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must explain on the record the basis for any position to the contrary. Finally, on administrative burden, the rule as written already contains exceptions, including for "the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency has not identified which specific burdens those exceptions fail to address. It must do so, with quantification, before rescission can stand as a proportionate response to any genuine operational difficulty. Future generations deserve to have this land, to experience the beauty the world has to offer, and we are discussing potentially opening the door to take that away.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Fishing lakes, rivers, creeks, and streams without roads cutting through the surrounding land is one of the few remaining privileges available to people willing to make the trek. That is not a small thing. The ecosystems and habitats that support the life in those waters only hold together because human intrusion has been limited. To continuously push the development of infrastructure where it is not needed will lead to the devastation of it all entirely. I hike and camp for the same reason: to experience wildlife as it is, to disconnect, to encounter nature without extreme human intrusion. A large majority of this country has already been developed for commercial, agricultural, and residential use. What remains unroaded and intact should stay that way. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule in full and ask the agency to answer the specific questions raised below. The agency justifies this proposal in part on wildfire and fuels management grounds, but its own record contradicts that justification. The agency found that "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." Opening more roadless acres to road construction under that finding is not a fire management strategy. I ask the agency to explain how the proposal departs from those prior findings and to reconcile the rescission with the ignition data in its own draft environmental impact statement, which the record shows reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is just as weak. The agency's own analysis shows that "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 those marginal gains, the agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. The agency cannot establish a net benefit from this action, yet it proposes to expand a road system already carrying a $6.9 billion maintenance backlog. The agency must explain, in plain terms, how that arithmetic supports rescission. The agency also argues that state-specific approaches can replace a single national rule. But the agency's own record acknowledges that it "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The last time the agency substituted local decision-making for the national rule, the Ninth Circuit found that approach legally deficient. The agency has not explained how this proposal avoids the same deficiencies, and it has not addressed its own prior finding that local decision-making can incrementally erode nationally significant roadless values. A clear answer to both points is required. Finally, the proposal argues that the 2001 rule exceeded the agency's statutory authority. That question has already been litigated. A federal appellate court reviewed the challenge to the rule and held, exercising jurisdiction under 28 U.S.C. Section 1291, that it would "REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency needs to state plainly what basis it has for a contrary position, given that a federal court has already ruled on this question. This land was meant to remain untouched and preserved. Preserving the national forests for their ecosystems and wildlife is just as important as any commercial use. The agency should answer each of these points in the final record before any action on this proposal is taken. Sincerely, Mary Landaberde Groveland, Florida

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Living in Arizona, I value the ability to hike in remote areas without roads. The Oracle Roadless Area, the Butterfly Roadless Area, the Santa Rita area, and really any roadless corner of the Coronado National Forest matters to me. These lands are national treasures, not a holding area for money making. I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The Coronado holds 23 inventoried roadless areas totaling 482,687 acres. Those areas, spanning the Santa Ritas, the Rincons, and the other sky island ranges, are the connective tissue between isolated mountain forests surrounded by hot desert. Jaguars have been documented crossing from Mexico through the Santa Ritas into the Rincon Mountains and beyond, using the roadless corridors between those ranges as the only pathways that make that movement viable. The Upper Rincon Roadless Area, the Santa Rita area at 6,078 acres, the Happy Valley area at 7,972 acres: these are not abstract inventory entries. They are the ground where that connectivity either holds or breaks. Opening them to new roads does not protect them. It fragments them. I ask the agency to explain on the record why it believes the rescission is consistent with its own documentation of these corridors as irreplaceable biological pathways. 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 cites wildfire management as a justification for rescission. That argument moves in the opposite direction from the agency's own findings. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask the agency to reconcile the rescission with those ignition figures and explain the departure from its prior findings. The proposal also rests on economic and employment grounds. The agency's own 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." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. It makes no sense at all to build new roads when the agency cannot even maintain the current roads. The existing maintenance backlog stands at $6.9 billion against a road budget of about $73 million a year. The agency must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already collapsing under that backlog. The agency's own record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The proposal argues that state-specific approaches can replace the national rule. That argument has been tested. The Ninth Circuit found that local decision-making can incrementally reduce nationally significant roadless values, and the state-by-state replacement was rejected. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres, and across the Southwestern region 739 municipal water intakes sit in watersheds containing affected roadless areas. What happens to those values under a patchwork approach is not a hypothetical. The agency must explain how this proposal avoids the deficiencies the Ninth Circuit identified when the national rule was last replaced with a state-by-state approach. Finally, the agency's record states: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The proposal argues that the 2001 rule exceeded statutory authority. The Tenth Circuit held that the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency owes a clear explanation of the legal basis for any position contrary to that holding, and it must provide one. Sincerely, Andrea C. Tucson, AZ

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas around Mt. Rose have been part of my life for 35 years. I have hiked with others and camped in or near Rose - Galena, Rose - Whites Canyon, Rose - Summit, and the Mt. Rose roadless area in the Lake Tahoe Basin Management Unit. I have paddled Lake Tahoe, a world-renowned treasure, and I have been privileged to spot the quite unique band-tailed pigeon in these mountains, along with grouse and other upland species. These places, the Galena drainage, White's Creek drainage, and the Mt. Rose summit country, make northwest Nevada unique. They draw millions of outdoor lovers now, an economic force that was a trickle when I moved here and is a major driver today. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. We have already seen wildfire in the Toiyabe up close, human caused as the population grows. The agency's own data on fire should stop this proposal The DEIS 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 offers wildfire management as a justification for rescission, while the agency's own draft environmental impact statement records the opposite. The Humboldt-Toiyabe is the largest national forest in the lower 48, scattered across mountain ranges rising from the Great Basin desert, each roadless range a sky island with its own ecology, its own water, its own wildlife. Roads into that terrain, according to the agency's own finding, multiply the chance of ignition. I ask the agency to explain why the proposal departs from its own prior findings on fire occurrence and to reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside these roadless areas. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. A federal appellate court already answered that question. Exercising its jurisdiction, the Tenth Circuit stated: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court held the rule was within the authority Congress granted and did not create de facto wilderness. The agency has not explained what has changed in the law since that ruling. I ask the agency to address the Tenth Circuit's holding and explain the legal basis for any contrary position it now takes. The rule already permits what the agency says it cannot do. The agency's own description states: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The proposal cites permitting and administrative burden as reasons to rescind the rule entirely, but the rule as written already carves out exceptions for public health and safety, existing mineral leases, and community wildfire protection. The agency has not identified which specific burdens fall outside those exceptions. Nevada holds 316 inventoried roadless areas totaling 3,186,206 acres, and the Humboldt-Toiyabe alone holds 354 inventoried roadless areas totaling 3,383,849 acres. Across the Intermountain region, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. Runoff into the Truckee from logging in the basin would be a disaster, and clean water from these drainages is not a burden, it is the point. The agency must identify, with specificity and on the record, which burdens are not already addressed by the rule's existing exceptions. Finally, the agency certified no significant impact on small entities while its own Cost Benefit Analysis records lost recreation benefit at a minimum of $6.1 million a year and its own DEIS names outfitters, guides, and tour operators as affected parties. . That is not a regulatory flexibility analysis; it is an averaging exercise designed to obscure the real harm. Much of the U.S. is still scarred by logging for the benefit of a few, while the many who depend on intact forests for their livelihoods and their lives are left with the damage. The agency should withdraw the certification and assess the actual impact on the small businesses operating within the potentially affected roadless areas. Sincerely, Susan Juetten Carson City, Nevada

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Pemigewasset Wilderness has been part of my family across three generations. I have gone since I was born, and it is meaningful to me, my parents, and my grandparents. Losing its purity would be a loss to family memory and to land I hope to share in an untouched form with my future kids. That is why I oppose the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) and ask the agency to address each of the following points in its final record. The White Mountain National Forest holds 16 inventoried roadless areas totaling 240,669 acres, including the Pemigewasset Wilderness, whose headwaters feed rivers running to the Connecticut, the Merrimack, and the Saco, supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. Across the Eastern region alone, 286 municipal water intakes sit in watersheds containing affected roadless areas. The New England mountains were clearcut once before, and the damage was so severe that Congress passed the Weeks Act of 1911 specifically to authorize federal purchase and recovery of those lands. These places, home to moose, black bear, brook trout, and Canada lynx, recovered under protection. The economic case for rescission does not hold together. The agency's own record states that "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 those marginal gains, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, a spread so wide it cannot establish a net benefit. Meanwhile the agency already carries a $6.9 billion maintenance backlog on roads it cannot afford to keep, against a road budget of roughly $73 million a year. I think it makes no sense to increase roads that we need to use taxpayer dollars to maintain. This is a terrible and poorly analyzed plan, and reducing long-term spending means doing it pragmatically, not expanding infrastructure the agency cannot sustain. I ask that the agency reconcile the proposal with these figures and explain how an action whose own analysis cannot demonstrate a net benefit justifies adding to a road system already buckling under deferred maintenance. The proposal argues that state-by-state approaches can replace a national rule. The agency's record itself states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit reviewed exactly that state-by-state alternative and found it deficient. I ask that the agency address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies identified the last time a national rule was replaced with a state-by-state approach. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. The court that examined that question reached a different conclusion. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held that it did not create de facto wilderness. The agency owes the record a direct explanation of any contrary legal position it intends to rely on. Finally, the proposal cites permitting and administrative burden as justifications for rescission. The rule as written already provides that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Additional exceptions address existing mineral leases and community wildfire protection. The agency has not identified which specific burdens fall outside those existing provisions. It should do so, with quantification, before any further action on this proposal. Public land should be managed for long-term value to the country and its people. The Pemigewasset Wilderness represents exactly that kind of value, accumulated across generations and irreplaceable once a road goes in. I ask the agency to answer each of these points in the record before it proceeds. Sincerely, Calvin Kinghorn San Francisco, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests where I hike are not abstract. I go to Ocala National Forest to see pristine wild landscapes, and when I visit family in California we hike in Sequoia National Forest to breathe clean air. These are not amenities. We live in an ecosystem, and the lands inside it should be preserved for the long-term survival of our children and our nation. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens exactly that, and I oppose it. The Ocala sits directly on top of the Floridan Aquifer. Alexander Springs, a first-magnitude spring in the heart of the forest, pumps 80 million gallons of crystal-clear water per day through karst limestone that makes any road construction a direct contamination pathway to the drinking water supply of central Florida. The forest holds 4,855 acres across 2 inventoried roadless areas. Red-cockaded woodpeckers recovered here from 7 breeding pairs to 98 family groups because the longleaf pine stands they need have never been fragmented by roads, and Florida scrub-jays, found nowhere else on the planet, depend on the surrounding scrub. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The scale of what this rescission puts at risk is not speculative; the agency's own inventory makes it legible. On wildfire, the proposal justifies rescission in part on fuels management grounds, yet 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." I ask that the agency explain why this proposal departs from that prior finding, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. This response is even more timely, given the increased fire frequency driven by climate change induced drought. On economics, the proposal also relies on timber and employment benefits, but the agency's own 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." The same record projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, while the existing road system already carries a $6.9 billion maintenance backlog. How does an action whose own cost-benefit analysis cannot establish a net benefit justify expanding that backlog? On the state-by-state approach, the proposal argues that local decision-making can substitute for a national rule, yet the record shows the agency itself once stated: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time the agency replaced the national rule with a state-by-state approach. Finally, on statutory authority, the proposal questions whether the 2001 rule exceeded the agency's legal power. The reviewing court answered that question: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit held that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must explain, with specificity, the legal basis for any contrary position before proceeding further. Cyrene Schweitzer Plantation, FL

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The rivers I paddle run through multiple wilderness areas, and that is not an accident. I go there to get away from cars, infrastructure, and noise. Silence and beauty warm the soul. The 2001 Roadless Area Conservation Rule protects the conditions that make those rivers worth paddling, and I oppose its rescission. Water is becoming more scarce as reduced precipitation is increasing. We do not need to mess up the only clean water we are getting these days. The agency's own record acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. More than 7,000 municipal water intakes sit in watersheds fed by roadless areas, and fewer than 12 percent of those watersheds have impaired streams today. Opening these areas to roads threatens to move them into the impaired column. I ask the agency to explain on the record how it weighs this sediment risk against the marginal economic return the proposal anticipates, given that the people downstream drinking that water have no substitute source to turn to. The economic case for rescission does not hold together even on the agency's own numbers. The agency has stated that "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." Those figures describe a marginal contribution to national supply. Against that, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, offset by recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. A range that wide cannot establish a net benefit. The agency must explain how expanding a road system already carrying a $6.9 billion maintenance backlog is justified when its own analysis cannot show the action pays. The wildfire rationale is no more persuasive. The proposal invokes fuels management to justify rescission, but the agency's own findings state that "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." If the goal is reducing fire risk, building roads works against that goal by the agency's own measure. The agency needs to reconcile the proposal with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The proposal also argues that state-by-state management can replace the national rule. The agency has already tried that approach. Its own record notes that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit reviewed that state-specific replacement and found it wanting. The agency owes the public an explanation of how this proposal avoids those same deficiencies, and an accounting of its own prior finding that local decision-making can incrementally erode nationally significant roadless values. Finally, the proposal questions whether the agency had authority to issue the 2001 rule at all. The courts already answered that question. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address the Tenth Circuit's holding that the 2001 rule fell within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and it must lay out in plain terms the legal basis for any contrary position it now advances. Humans demand multiple resources from forest ecosystems, and not every ecosystem can be managed for all needs. Wilderness areas should be managed to be wild. Roads are not needed there. The agency has not demonstrated otherwise, and rescission should not proceed. Sincerely, Barbara

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Mount Olympus near Salt Lake City is a unique and special place for the million-plus people living in the region. I was married near Boulder Mountain, in the Dixie National Forest, and it is a gorgeous and special place that needs to remain protected. So many of the unique wild areas of Utah and surrounding states are protected by the roadless rule. The rescission of the 2001 Roadless Area Conservation Rule would put all of these places, and the other roadless areas in Utah I am naming here, at serious risk. I oppose Docket FS-2025-0001 for the reasons below. These regions bring huge amounts of tourism income to Utah and contribute to making it the amazing and unique place that it is. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres, and across the Intermountain region 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The people of Salt Lake City depend on the landscape that includes the 9,982 acres around Mount Olympus and the 6,157 acres at Twin Peaks, both in the Wasatch-Cache National Forest, for clean water and for the outdoor character that defines the place. The 110,690 acres of Boulder Mountain, Boulder Top, and Deer Lake, and the 19,581 acres of Table Cliffs and Henderson Canyon, both in the Dixie National Forest, are part of the same connected system of protection. Rescinding the rule would expose all of this to road construction and the impacts that follow. The agency's stated justification includes wildfire and fuels management, but its own record contradicts that rationale. The agency has found: "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." Given that finding, the proposal's premise that opening roadless areas to road construction serves fire management goals is not coherent. The agency must explain why this proposal departs from its own prior findings, and it must reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. On economics, the agency has acknowledged: "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." The record 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, with a net present value spanning -$92 million to +$199 million, while the existing road system already carries a $6.9 billion maintenance backlog. The agency has not shown that this action produces a net benefit, and it owes the public a direct accounting of how expanding a road system under those fiscal conditions is justified by the numbers in its own cost-benefit analysis. The proposal argues that state-specific approaches can substitute for a national rule, but this path has been tried before. The agency's own record reflects "its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." What the record does not explain is how a state-by-state replacement avoids the deficiencies that led a federal appellate court to reject that approach the last time the agency tried it, and the agency's prior own finding that local decision-making can incrementally erode nationally significant roadless values. The agency should answer that question squarely. Finally, the proposal questions the statutory authority behind the 2001 rule. The courts that reviewed this directly held otherwise. The Tenth Circuit stated: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency has not explained in this proposal what legal basis supports a contrary position, and it should.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas of Mark Twain National Forest in Missouri, and the forests I frequent across California, including Mount Shasta, Sequoia, Sierra, Stanislaus, and Los Padres, are places I seek out precisely because they are roadless. Self-powered access and minimal human disturbance are not incidental features; they are the reason I go. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). These are the last pristine areas in the country. Public land should be managed for the benefit of wildlife and conservation of natural resources, not for financial gain or short-sighted priorities. The proposal before the agency fails that standard on its own terms, and I ask the agency to address the following: The wildfire rationale offered for rescission contradicts the agency's own record. The agency's prior findings state: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildfire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The forests I use in California sit in precisely the kind of high-risk terrain that sentence describes. The agency must explain why the proposal departs from these prior findings and reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is no stronger. The agency's own record acknowledges that "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 baseline, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. That range cannot establish a net benefit. The agency must explain how expanding a road system already carrying a $6.9 billion maintenance backlog is justified when the analysis it commissioned cannot show the action pays. The proposal also argues that state-specific rulemaking can replace one national rule, but the agency's own record reflects a prior attempt in exactly that direction. The record states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all-nationwide rulemaking approach.' 70 Fed.Reg.at 25,656." Missouri alone holds 25,453 acres across its inventoried roadless areas, and the Eastern region, which includes Missouri, has 286 municipal water intakes sitting in watersheds containing affected roadless areas. Those values are national in scale and cumulative in character; local decision-making can incrementally reduce them. The agency must explain how this proposal avoids the deficiencies the Ninth Circuit identified when the agency last substituted a state-by-state approach for the national rule. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. That question has already been litigated. A federal court of appeals held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and concluded it did not create de facto wilderness. The agency must state plainly the legal basis for any contrary position. I support retaining the 2001 Roadless Area Conservation Rule without modification. Sincerely, Elizabeth Cooley Imperial, Missouri

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas across the Mendocino and Los Padres National Forests are the reason I am filing this comment, and I want the agency to understand what is at stake before it acts. Reister Canyon, Snow Mountain, Skeleton Glade, and Briscoe on the Mendocino, and Black Butte, Bear Mountain, Camuesa, Tequepis, Condor Point, Little Pine, Santa Cruz, and Diablo on the Los Padres, represent the kind of unroaded California landscape that the 2001 rule was written to protect. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. Rescinding the rule puts all of that at risk, and the agency has not made a credible case that it should. The proposal claims the 2001 rule exceeded the agency's statutory authority. That claim was already litigated. A federal court of appeals addressed it directly and held otherwise, reversing the lower court's grant of injunctive relief: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must explain on the record the basis for any contrary legal position it now intends to assert, because simply declaring the authority question open does not make it so after a circuit court has resolved it. The agency also argues that the rule creates permitting and administrative burdens that justify rescission. The rule's own text answers that argument. The prohibition on road construction was never absolute: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The rule as written already accommodates existing mineral leases and community wildfire protection needs. The agency is required to identify, specifically and on the record, which burdens are not already addressed by those existing exceptions, and to quantify them. A general assertion of burden is not analysis. The regulatory flexibility certification is a separate problem. The proposed rule certifies no significant impact on small entities, yet the agency's own DEIS names outfitters, guides, and tour operators as affected, and its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The certification reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in areas like Santa Cruz, Condor Point, and Diablo. That approach makes the arithmetic come out small by design. The agency should withdraw the certification and conduct a proper assessment of the small entities actually operating in the potentially affected roadless areas, not a national average firm who may never have set foot in any of them. Finally, the proposal itself invites comment on reliance: it 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. Under settled administrative law, an agency changing an existing policy must assess the reliance interests its prior rule created, not merely invite comments about them and then ignore what it receives. This comment is one such interest. The areas I have named, across two national forests in California, are places whose roadless character I have relied on the 2001 rule to preserve. The agency must identify and weigh the reliance interests described in the comments submitted in this docket, including this one, before it takes any final action. The agency should not proceed with rescission. If it does proceed, it must answer each of the specific legal and analytical failures identified here before any final rule takes effect. Sincerely, Claire L San Francisco, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, because the record the agency assembled does not support this action. I live in Oregon. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres, and 1,522 municipal water intakes across the Pacific Northwest region sit in watersheds containing affected roadless areas. Opening roadless land to extraction when the agency's own data say the costs outweigh the gains is not wise. The deer I watch from my window depend on roadless land more than many people realize. The agency's own DEIS cites research finding that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed. The Tribal Summary Impact Statement in the agency's own record credits the rule's protection with the recovery of deer populations in Alaska by preserving old-growth winter shelter. Rescinding the rule puts exactly that kind of roadless security at risk for deer across the country. I ask the agency to explain in this proceeding how it weighs documented harms to deer against any claimed benefit of the rescission. The birds I enjoy watching and listening are also at stake. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Roads do not have to carry vehicles to harm birds; their noise alone does measurable damage. I want the agency to explain how it reconciles those findings with a proposal to expand the road system into areas currently protected. 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 roadless lands." The proposal nevertheless cites wildfire and fuels management as justification for rescission. Those two positions cannot both be right. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence and reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the protected roadless areas. The economic case for this rescission is weak. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total U.S. 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." Numbers support me in saying the public wants wild habitats preserved, and those numbers show the extraction gains are trivial. The agency's own 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, with a net present value spanning negative $92 million to positive $199 million, and the Forest Service already carries a $6.9 billion road maintenance backlog. The agency must reconcile the proposal with an economic analysis that cannot establish a net benefit. Explain how adding to a road system already in deficit serves the public interest. The agency also argues that state-by-state approaches can replace a single national rule. Its own prior record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit has already reviewed what happened when the agency substituted local decision-making for the national rule and found it deficient. The agency needs to explain in this proceeding how this proposal avoids repeating those same deficiencies. Finally, the agency claims the 2001 rule exceeded its statutory authority. The Tenth Circuit already examined that question and held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the rule was within the authority Congress granted and did not create de facto wilderness. The agency must address that holding directly and state on what basis it now takes a contrary position. Public land should be managed for citizens, not for benefit of cattle ranchers, data center managers, or oil and gas drillers. Our lives are greatly enriched sharing this planet with our wild friends, and the record before this agency does not justify trading that away for gains its own analysis cannot confirm. Sincerely, Jean M. Winslow Newport, OR

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Colorado holds 4,407,277 acres across 326 inventoried roadless areas, and the people of this state have made clear what those landscapes mean to them. Ninety-three percent of Colorado's residents watch wildlife, most of them every day. They understand that abundant, healthy, well-managed wildlife populations improve quality of life, and that well-planned conservation and protection of natural resources makes Colorado a great place to live, work, and recreate. I share that view, and it is the foundation of this comment opposing the proposed rescission of the 2001 Roadless Area Conservation Rule. The Pike-San Isabel National Forest holds two of the roadless areas I am writing through: Old Monarch Pass, at 19,531 acres, and Porphyry Peak, at 3,394 acres. Old Monarch Pass already provides access through a backcountry road experience. Another road would not provide a different experience, and the case for protecting the Pike-San Isabel from unnecessary development does not require elaboration beyond that. At Porphyry Peak, Colorado's high mountain tundra is easily damaged by vehicle traffic across sensitive tundra plants, and off-roaders in this state already have a wealth of places to pursue motorized activities. The 3,613-acre Dorsey Creek area in the Rio Grande National Forest sits at the headwaters of drainages that supply clean water downstream. Colorado is the headwaters for much of the nation, and clean, clear streams like Dorsey Creek provide a resource we simply cannot live without. Across the Rocky Mountain region, 325 municipal water intakes sit in watersheds containing affected roadless areas. The agency must explain, specifically and directly, what this rescission means for the integrity of those watersheds and what substitute protections, if any, it proposes. The agency's own language undermines its stated justification on wildfire. The 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." I ask the agency to explain why the proposal departs from that prior finding, and to reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is equally difficult to sustain on the agency's own numbers. The record acknowledges: "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." The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, all while the existing road system carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with those figures and explain how expanding a system it cannot afford to maintain serves the public interest. The legal history here is not favorable to rescission either. The agency's own record recounts that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That dissatisfaction was tested in court, and the state-by-state approach that replaced the national rule was struck down. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time this substitution was attempted. On the question of statutory authority, the Tenth Circuit has already spoken: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court held the 2001 rule was within the authority Congress granted and did not create de facto wilderness. The agency must explain the legal basis for any contrary position. We don't need more roads. We need more Wilderness. The agency should respond to each of the concerns raised here and place those responses in the public record before any final action is taken. Sincerely, John Koshak Penrose, CO

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking is when I feel most at peace and in awe of the world. These roadless areas are what make that possible, and the agency's proposal to rescind the 2001 Roadless Area Conservation Rule threatens them in ways the agency's own record does not support. The agency argues that opening roadless areas to road construction would help manage wildfire. Its own findings say the opposite. The agency's 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 agency must explain what changed. Its own DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask that the agency explain, clearly and in the rulemaking record, why this proposal departs from those prior findings and how it reconciles the rescission with the ignition data its own analysis produced. The agency also cannot make the economics work. Its own record acknowledges: "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." The agency's own 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 ranging from -$92 million to +$199 million. That range does not establish a net benefit. The agency's road maintenance backlog already stands at $6.9 billion. How does the agency justify expanding a road system it cannot afford to maintain, for commodity yields that by its own numbers are a fraction of national production, when its own analysis cannot confirm the action pays? The agency argues that state-by-state approaches can replace a single national rule. But the agency's own record reflects its prior position: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit reviewed the last time the agency substituted state petitions for the national rule and found it deficient. The agency has already found that local decision-making can incrementally erode nationally significant roadless values. This proposal must address what is different now, and explain how it avoids the specific deficiencies identified in that prior litigation. The agency also suggests the 2001 rule exceeded its statutory authority. The courts that examined this question did not agree. The record includes the following holding: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit held that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must state in the rulemaking record the legal basis for any position that contradicts that holding. Clean water connects all of this. Without clean water we cannot survive and thrive. These roadless watersheds are part of what keeps water clean, and the agency's own analysis shows that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency must explain what specific protection will replace the 2001 rule for the municipal water intakes and drinkers who depend on these watersheds, and it must do so with analysis, not assertion. I oppose rescission of the 2001 Roadless Area Conservation Rule and ask that each of these points receive a substantive response before any final action is taken. Sincerely, Lyla Rothschild Tucson AZ 85719

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forest areas where I walk my dog and camp in primitive sites are the kind of country this rule was written to protect. I am opposing the proposed rescission of the 2001 Roadless Area Conservation Rule. The agency's own record contains a finding I want addressed directly. "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 justifies rescission partly on wildfire and fuels management grounds, yet this language comes from the agency itself. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which the record indicates reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not hold together either. The agency's own record states that "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." The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. The Forest Service is already $6.9 billion behind on maintaining the roads it has, against a road budget of roughly $73 million a year. My view is simple: take care of the existing roads. Building new roads into country that has none, when the agency cannot maintain what it already manages, adds cost without a demonstrated return. I ask that the agency explain, with specificity, how an action whose own cost-benefit analysis cannot establish a net benefit justifies further expanding a road system already carrying that backlog. The proposal argues that state-specific approaches can replace the national rule, but this ground has already been tested. The agency's own record acknowledges "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit reviewed that prior attempt to substitute state-by-state management for the national rule and found it wanting. The agency has not explained how this proposal avoids those same deficiencies or addressed its own prior finding that local decision-making can incrementally erode nationally significant roadless values. That question deserves a direct answer in this record. On the question of statutory authority, the Tenth Circuit already reviewed whether the 2001 rule exceeded the agency's power and held otherwise, reversing a permanent injunction and remanding to vacate it. The court's ruling was clear: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit specifically found the rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not find that it created de facto wilderness. The agency's current proposal rests in part on a contrary statutory reading. The agency must explain in this record what basis it has for that position in light of that holding. My children enjoy the outdoors and nature. I want my grandchildren to have as much opportunity as I did. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. That asymmetry is itself a reason this record is inadequate. The agency should answer each of the specific points raised above before any final action is taken. Sincerely, Christine Cavender Clermont, FL

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Going into nature is how I stay connected to my own humanity and to my place on this small, fragile planet. It grounds me and allows me to feel the connection we share with all things that are part of our home. Part of that for me is learning to identify bird calls and observing wild animals at a respectable distance. The birds I try to identify live in forested habitat that depends on the absence of roads, and the agency's own record makes that dependency plain. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask the agency to respond to each of the points below. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The agency is proposing to open these landscapes to road construction while its own science documents what roads do to the birds that live there. I want to know how the agency accounts for that harm, and I ask that it respond in the record to how these findings factor into the decision. The proposal invokes wildfire management as a justification for rescission, but the agency's own DEIS 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." That finding cuts directly against the argument the agency is making. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case is equally difficult to square. The agency's own 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." The agency projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, and this is before accounting for a road maintenance backlog already standing at $6.9 billion. The agency's own Cost Benefit Analysis cannot establish a net benefit. I ask that it reconcile the proposal with those numbers and explain how expanding a road system already carrying that backlog is justified by revenues this small. On the question of state-specific alternatives to a national rule, the agency's own record notes that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency tried this before and the Ninth Circuit rejected it. The agency has its own prior finding that local decision-making can incrementally reduce nationally significant roadless values. This proposal does not address that deficiency, and the agency should explain how it avoids repeating it. Finally, the proposal argues that the 2001 rule exceeded statutory authority. The Tenth Circuit addressed that question directly and held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency owes the public a clear explanation of the legal basis for any position contrary to that holding. The forests I walk in to stay connected to this planet, and the birds I listen for there, depend on these protections remaining in place. The agency should not rescind this rule without answering each of these questions directly. Sincerely, Katie O’Brien Rohnert Park, California

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Tribal consultation is incomplete and its summary is withheld from comment The consultation owed to Tribal governments is owed to tribal members such as myself (Native Village of Kwinhagak), and it is not finished. The agency's own record says so: The Forest Service received 64 requests for Tribal consultation; 29 consultations have been held and 5 more scheduled, with the published Tribal Summary Impact Statement records that the majority sentiment among consulted Tribal governments is opposition, viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival and the ecological health of ancestral homelands; the final Tribal Impact Summary Statement is deferred to the final rule. Tribal governments proposed alternatives, including a strengthened roadless rule and a Traditional Homelands Conservation Rule, and none was analysed; the final impact statement arrives only when comment is closed. I ask that the agency complete all 64 requested consultations and publish the Tribal Impact Summary Statement for public comment before any final rule. Issue 2: Wildfire The proposal justifies rescission in part on wildfire and fuels management grounds. 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." (Roadless Area Conservation FEIS Vol. 1 (Nov. 2000), fire-occurrence discussion, printed p. 3-115) "The net result is that there is a substantially increased level of fire occurrence outside inventoried roadless areas." (Roadless Area Conservation FEIS Vol. 1 (Nov. 2000), text introducing Table 3-19 (human-caused fire occurrence 1986-1996), printed pp. 3-104 to 3-105) I ask that the agency explain on the record why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement (DEIS Table 21), which reports far higher fire density on roaded land than inside the affected roadless areas. Furthermore, there are multie studies that demonstrate how old growth forests are resistent to the types of large-scale fires we are witnessing in parts of Canada (often attributed to outdated logging practices and monocultures) as well as the states. Issue 3: A court already said they had the authority The proposal argues that the 2001 rule exceeded the agency's statutory authority. The courts that reviewed that question held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." (Wyoming v. USDA, 661 F.3d 1209 (10th Cir. 2011), disposition (slip op. p. 4)) "In sum, we conclude that the Roadless Rule did not designate de facto administrative wilderness areas in contravention of the procedures set out in the Wilderness Act." (Wyoming, 661 F.3d 1209, Wilderness Act holding (slip op. pp. 34-35)) I ask that the agency address the Tenth Circuit's holding that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act (MUSYA) and did not create de facto wilderness, and that it explain on the record the basis for any contrary position. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Nastasia C. Palmer, AK

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Public lands must be managed with a sharp eye toward preservation and protection for generations to come, not exploited as assets on a balance sheet. That is not a sentiment. It is the standard against which this rescission fails, and I am writing to oppose it. I live adjacent to State Forest lands on five wooded acres. Despite my disability, birdwatching is accessible to me precisely because the landscape around me still functions. Over the last decade, as building increased habitat loss, I have watched the diversity of my local bird population decline. Tufted titmice, white-breasted nuthatches, American goldfinches, Eastern bluebirds, black-capped chickadees, mourning doves, hummingbirds, turkeys, northern flickers, and hawks still use the property, as do foxes, deer, and chipmunks, year after year treating it as a nursery. That word, nursery, is the right one. What I watch on five wooded acres depends on what is protected at scale. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The wild turkeys that cross my land, and the complex forest structure they depend on for mast, are named in the DEIS among the species that lose the most when that structure is broken. The deer that use my property as a nursery face disrupted migration routes and lost unroaded security if this rescission proceeds: the agency's own record, citing Wyoming research, documents that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed. I ask the agency to explain in this proceeding how those documented effects on birds and deer are consistent with a decision to open roadless areas to road construction. The wildfire rationale offered for this rescission cannot be reconciled with the agency's own record. The DEIS 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." If the agency is using fire management to justify rescission, it must explain why its proposal departs from that finding and reconcile the proposed action with the ignition data in DEIS Table 21, which the record shows reports far higher fire density on roaded land than inside the affected roadless areas. On the economics, the agency's own 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." Selling timber from these areas has always been a losing proposition. Water once fouled never returns to purity regardless of remediation, and the record projects timber revenue of $5.2 to $11.4 million a year to the Forest Service against recreation losses of at least $6.1 million a year and a net present value whose own range spans from negative to positive. The agency must explain how expanding a road system already carrying a $6.9 billion maintenance backlog is justified when its own Cost Benefit Analysis cannot establish a net benefit. The state-by-state approach advanced here has a history. The agency's record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That approach was tried and the Ninth Circuit found it wanting. The agency needs to confront its own prior finding that local decision-making can incrementally erode nationally significant roadless values and explain how this proposal avoids the same deficiencies. On statutory authority, the Tenth Circuit was direct: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court held the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The agency must explain the basis for any contrary position and address that holding squarely. The Roadless Rule was implemented to stop and prevent degradation of our watersheds and our forests. Rescinding it, on economic justifications the agency's own numbers undercut and on wildfire logic the agency's own data contradict, is not management. It is the balance-sheet thinking that public lands were never meant to serve. Sincerely, Beth Conry Milford, Pennsylvania 18337

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Vernal pools hold time still. Kneeling at the edge of one to record frog eggs and salamander larvae, watching the water catch light through an unbroken canopy, I understand exactly what is at stake in this proposal. I am a volunteer wildlife monitor for vernal pools, those ephemeral bodies of water that are home to the eggs and larvae of frogs and salamanders. Several pools I monitor are in the Jefferson National Forest. These pools, and the animals that use them, depend on a healthy forest ecosystem, which means an intact forest. I also use the Jefferson and George Washington National Forest to hike, camp, photograph the natural world, and soak in the wonder of these special places. I go roaming in the forest with my grandchildren and introduce them to what I can only call magical ground. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask that the agency take my concerns seriously and answer them in the record. The agency justifies this rescission in part on wildfire and fuels management grounds, but its own prior findings cut directly against that rationale. The rule's 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 vernal pools I monitor in the Jefferson depend on a stable forest structure that repeated ignitions would degrade, and the salamanders and frogs that breed in those pools have no refuge if the surrounding forest burns at uncharacteristic intensity. The agency must explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and it must reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic justification for this rescission is equally difficult to square with the agency's own analysis. The record before the agency 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 baseline, the agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, and the road system the agency proposes to expand already carries a $6.9 billion maintenance backlog. The forests where I monitor pools and hike with my grandchildren generate real, lasting value for people precisely because they remain intact. The agency must explain on the record how an action whose own economic analysis cannot establish a net benefit justifies expanding a road network the agency cannot currently afford to maintain. The agency also argues that state-specific approaches can substitute for the national rule, but this ground has already been tested. The record reflects that the USDA previously "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That state-by-state approach was challenged and rejected in court. The agency must address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and must explain how this proposal avoids the deficiencies identified the last time it substituted a patchwork of state rules for uniform national protection. Finally, the agency's suggestion that the 2001 rule exceeded its statutory authority is contradicted by judicial review of precisely that question. The court held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit upheld the rule as within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held that it did not create de facto wilderness. The agency owes the public a plain statement of the legal basis for any position contrary to that holding before it proceeds further with this rescission. Sincerely, Alison Nichols Roanoke, Virginia

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The country my family has lived in for generations is disappearing. What my ancestors enjoyed, I think will vanish in my lifetime. Rescinding the 2001 Roadless Area Conservation Rule will accelerate that loss, and I oppose it without qualification. I visit the Selkirk grizzly bear recovery area in northeastern Washington and the many roadless areas in the central Washington Cascades because roadless habitat is where wildlife has a genuine chance to recover from the pervasive, negative impacts already pressing down on every ecosystem. Habitat loss and degradation is the primary driver of extinction and extirpation, and roadless designation is one of the few tools that allows habitats to recover ecosystem function and provide necessary refuge. The agency's own draft environmental impact statement draws directly on the federal grizzly recovery plan to note that the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and that shooting, habituation and food reward all increase with the use of even secondary unpaved roads. Washington alone holds 139 inventoried roadless areas totaling 2,014,832 acres. Opening that network to roads puts grizzly recovery and many other species at direct risk, and I ask the agency to explain what mitigation it proposes that would be more protective than the rule it is eliminating. I am a third-generation wildland firefighter. My family has watched fire behavior change to extremes we see today. The agency ignores its own science and firefighters when it justifies opening roadless areas on fire-management grounds. 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." More roads means more human-caused ignitions, more fires for already-stretched crews, and more firefighters exposed to injury, long-term disability, and death. The agency must explain on the record why this proposal departs from its own prior findings on fire occurrence in roadless areas and reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. Out west, we have snow driven hydrographs where water supply depends on intact forests holding snowpack and regulating flow across the year. Across the Pacific Northwest region, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis establishes that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency should explain how introducing roads into currently intact watersheds is consistent with its water quality obligations. The economics of this proposal do not hold together. The agency's own record states that "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." The agency's current reorganization plan justifies the closure of national forest offices and research facilities citing its facilities budget. Rescinding the rule would add road miles to a system already carrying a $6.9 billion maintenance backlog against a road budget of about $73 million a year. There is no transparency in how the administration is justifying additional expenditure while cutting costs everywhere else. The agency must reconcile the proposal with its own cost-benefit analysis and explain on the record how an action whose own numbers cannot establish a net benefit is consistent with responsible stewardship. On the question of statutory authority, the Tenth Circuit has already spoken, holding: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency should address that holding, which found the 2001 rule within the authority Congress granted and held that it did not create de facto wilderness, and state plainly what legal basis supports a contrary position now. Finally, a significant portion of the roadless areas in Washington are adjacent to industrial timber companies that would benefit enormously from rescission. Civilian public servants are held to high ethical standards. I ask the agency to address on the record what conflict-of-interest review was conducted before this proposal was advanced.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The George Washington National Forest is where I go to recharge. I hike and camp there, and fall is my favorite season because of the mild temperatures and the colorful leaves. The forest is peaceful because there aren't many roads there. Southern Massanutten, where I live, is part of that beauty. Adding roads would drastically change this environment. I am asking you to keep the Roadless Rule fully intact. I love watching and listening to birds in the forest. Their calls are calming, and research has shown that listening to birds can reduce stress levels, positively impact mood, and improve cognitive function. The agency's own environmental analysis confirms what I experience: the DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. I also watch deer in these woods. The DEIS itself cites research finding that roads built for resource extraction may have altered mule deer migration routes and increased their movement speed, with the agency's own analysis identifying disrupted migration and lost unroaded security as the danger. Virginia holds 64 inventoried roadless areas totaling 393,682 acres, including Southern Massanutten, Gum Run, Oak Knob, Dry River, and Skidmore in the George Washington. Every road opened into these areas narrows the habitat birds and deer depend on. I ask the agency to explain, with specificity, how this rescission is compatible with what its own DEIS documents about roads and wildlife. Nothing is more important than clean drinking water. Rescinding the Roadless Rule would negatively impact the safety and availability of drinking water, and that is unacceptable. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of those watersheds have impaired streams today. Opening these roadless areas risks the majority that are still clean. The agency must explain what it intends to do to protect those watersheds if the rule that protects them is gone. If a road went into Southern Massanutten, I would be devastated. It doesn't make sense to create new roads when current roads aren't able to be maintained well. The agency is already carrying a $6.9 billion maintenance backlog on a road budget of roughly $73 million a year. The agency's own record states that "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." The agency must reconcile the proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain on the record how an action whose own numbers cannot establish a net benefit justifies expanding a road system already collapsing under its maintenance burden. The proposal also rests on a wildfire justification that the agency's own data contradicts. The DEIS 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 agency must reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why the proposal departs from this finding. Finally, the claim that the 2001 rule exceeded statutory authority is contradicted by the courts that reviewed it. The Tenth Circuit held, exercising jurisdiction under 28 U.S.C. Section 1291: "we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the rule within the authority Congress granted under the Organic Act and MUSYA, and found it did not create de facto wilderness. The agency has not explained what legal basis exists for a contrary position, and it should. Public land must be protected from development. The forest is peaceful because there aren't many roads there. Please don't change this. Sincerely, Katie in Massanutten, VA