Read the comments.

I am a rock climber, whitewater kayaker, angler, hiker, mountain biker, hunter, and equestrian who uses inventoried roadless areas constantly, and I do volunteer trail work myself. I also have a friend whose primary job is conducting professional fishery surveys on rivers like the Colorado, and another friend who works for the U.S. Geological Survey doing sonar-based hydrographic surveys — work that depends directly on the low-sediment water conditions this rule would put at risk. This rule guts the resource all of that depends on, and it should be withdrawn. USDA's own numbers admit near-term timber gains would be "modest and localized," yet the rule could impose over $100 million/year in net costs, including $6.1 million annually in lost recreation value — while the agency already carries a $6.9 billion road/bridge maintenance backlog it can't fund. You're proposing to build more roads you already can't maintain, to chase benefits you can't quantify. That's not policy, it's vandalism with a cost-benefit annex. This isn't a close legal call. USDA's rationale — that NFMA forest-level planning, not a national rule, is the right vehicle here — is the exact argument Wyoming made trying to kill this rule, and the exact argument the Tenth Circuit rejected in Wyoming v. USDA, 661 F.3d 1209 (10th Cir. 2011), holding nothing in NFMA "precludes national action on a conservation issue within the power of the Forest Service," and reinstating the Rule nationwide. Kootenai Tribe v. Veneman, 313 F.3d 1094 (9th Cir. 2002), and California ex rel. Lockyer v. USDA, 575 F.3d 999 (9th Cir. 2009), went the same way. USDA is relitigating a theory that has already lost twice. Under State Farm, 463 U.S. 29 (1983), and Encino Motorcars v. Navarro, 579 U.S. 211 (2016), an agency reversing a 25-year policy with entrenched reliance interests owes a "more detailed justification," not less. USDA's own preamble instead asks commenters to do its reliance analysis for it. That is precisely the abdication those cases forbid. Roadless watersheds supply drinking water to roughly 25 million Americans (PLOS Water, 2026) — over a third of Colorado's and New Mexico's populations. An onX analysis found 99% of Wyoming's roadless acreage functions as elk security habitat, the exact kind of low-road-density cover big game and Pittman-Robertson-funded wildlife management depend on. Roads and logging degrade the cold, clean headwaters that trout, salmon, and steelhead need, undermining Clean Water Act antidegradation protections (40 CFR §131.12) and, for anadromous fisheries, Magnuson-Stevens Essential Fish Habitat obligations. Whitewater and scenic values on Wild and Scenic-eligible rivers running through these areas are equally at risk. The wildfire justification doesn't hold up either: risk to communities is concentrated in the wildland-urban interface, which the agency can already treat under existing exceptions, not in remote backcountry this rule would newly expose to roads. USDA's own notice admits the "majority sentiment among Tribal governments consulted is opposition," citing threats to sacred sites, subsistence resources, and treaty rights, and admits a failure to fulfill trust and consultation obligations — obligations that carry the "highest responsibility and trust," Seminole Nation v. United States, 316 U.S. 286 (1942). ANILCA §810 requires a subsistence evaluation before, not after, action in Alaska. And procedurally: this comment period is 30 days with zero public hearings, following a truncated 21-day notice period on which 99% of 220,000+ comment letters opposed rescission. The 2001 Rule was built on 600+ hearings and 1.6 million comments. That is not a good-faith effort to hear from the public — it's a box-checking exercise on the way to a predetermined outcome. Withdraw this rule. If site-specific flexibility is genuinely needed, the existing state-petition process (5 U.S.C. §553(e); 7 CFR 1.28) already used by Idaho and Colorado is the right tool — not eliminating baseline protection for 44.7 million acres of the last big wild country left in the National Forest System. Full legal analysis, additional statutory citations (Wild and Scenic Rivers Act, Clean Water Act, Magnuson-Stevens Act, Pittman-Robertson Act, National Trails System Act, NEPA, ESA), and complete source list are provided in the attached comment letter, which I incorporate by reference.