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Re: RIN 0596-AD66 — Proposed Rescission of the 2001 Roadless Area Conservation Rule I oppose rescission of the 2001 Roadless Area Conservation Rule and request that the Forest Service retain the Rule or adopt substantially narrower alternatives. Rescission would remove national protection from approximately 58.5 million acres of Inventoried Roadless Areas after roughly 25 years. This would eliminate a landscape-level safeguard intended to prevent incremental fragmentation of roadless lands. Administrative Procedure Act and NEPA The Forest Service must provide a reasoned explanation for reversing longstanding policy and address important aspects of the problem, including reliance interests. Motor Vehicle Manufacturers Association v. State Farm, 463 U.S. 29 (1983); FCC v. Fox Television Stations, 556 U.S. 502 (2009). The Ninth Circuit has recognized that roadlessness itself has environmental significance, independent of wilderness designation. Smith v. U.S. Forest Service, 33 F.3d 1072, 1078–79 (9th Cir. 1994). It is therefore not enough to state that future projects will remain subject to NEPA. Project-level review cannot substitute for a national protection preventing incremental fragmentation. The EIS should analyze cumulative consequences of rescission, including road construction, timber harvest, habitat fragmentation, watershed impacts, wildlife connectivity, recreation, and loss of roadless character. Wildfire The proposal relies substantially on wildfire and forest-health concerns, but those concerns do not establish that nationwide rescission is necessary. Roads can improve access for some suppression and fuel-treatment activities, but can also increase human access and ignition risk, fragment habitat, facilitate invasive species, and create permanent maintenance obligations. The Forest Service should quantify the net wildfire effect rather than assume that additional roads necessarily reduce risk. The agency should evaluate whether fuel reduction and wildfire-response objectives can be achieved through existing roads, temporary access, targeted exceptions, or geographically limited amendments. It should also address recent research finding substantially greater wildfire ignition density near roads than in Inventoried Roadless Areas. Oregon Oregon contains extensive roadless lands on the Deschutes, Ochoco, Willamette, Mt. Hood, Umatilla, Wallowa-Whitman, Rogue River-Siskiyou, Fremont-Winema, and Siuslaw National Forests. These areas provide connected habitat, watershed protection, recreation, hunting, fishing, and solitude that cannot be recreated once permanent roads fragment them. This is particularly important in Central Oregon. Roadless landscapes around the Three Sisters, Mt. Jefferson, Paulina, Bachelor, and Metolius watersheds are part of the ecological and recreational landscape on which Central Oregon communities depend. The Forest Service should identify Oregon roadless areas vulnerable to new roads or commercial timber activity and the resulting cumulative effects. Alternatives and fiscal consequences Greater managerial flexibility does not itself establish that rescission is necessary. The Forest Service should evaluate retaining the Rule, targeted wildfire or forest-health amendments, geographically limited exceptions, temporary rather than permanent roads, and forest-plan-specific amendments. If these alternatives are inadequate, the agency should explain why with site-specific evidence. The proposal acknowledges a substantial backlog in Forest Service road and bridge maintenance. Before expanding the road system, the agency should quantify construction, maintenance, erosion, closure, and decommissioning costs and identify funding sources. Request I request that the Forest Service: 1. Retain the 2001 Roadless Rule unless it can demonstrate a legally and scientifically sufficient basis for rescission. 2. Address the Ninth Circuit’s recognition that roadlessness itself has environmental significance. 3. Quantify cumulative environmental consequences of foreseeable road construction and timber harvest. 4. Rigorously analyze roads’ competing wildfire-suppression and ignition effects. 5. Identify Oregon roadless areas and specific management needs allegedly requiring rescission. 6. Meaningfully evaluate narrower alternatives. 7. Address reliance interests created by 25 years of roadless protection. 8. Account for the fiscal consequences of expanding an already maintenance-constrained road network. The Forest Service should not equate increased managerial discretion with demonstrated environmental benefit. If the record cannot establish that rescission advances the agency’s responsibilities after accounting for cumulative consequences, the agency should retain the Roadless Rule. Thank you for including this comment in the administrative record for RIN 0596-AD66.