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FORMAL PUBLIC COMMENT — PROPOSED RESCISSION OF 2001 ROADLESS RULE Docket Number: 2026-18648 October 6, 2026 TO THE U.S. FOREST SERVICE AND DEPARTMENT OF AGRICULTURE: I, Lionel P. Trepanier (lioneltrepanier@gmail.com, Palm Desert, CA 92211), submit this comment in strong opposition to rescission of the 2001 Roadless Area Conservation Rule. I am a 25-year participant in Forest Service rulemaking, having submitted comments on 100+ USFS projects including the Roadless Rule and Spotted Owl EIS. VIOLATION OF LAW This rescission violates the Administrative Procedure Act, National Environmental Policy Act, Endangered Species Act, and Federal Indian Law on multiple independent grounds: 1. APA VIOLATION—Arbitrary and Capricious: The agency's own Draft EIS states: "Road density is linked to human-caused wildfires, and as density of roads increases so does probability, number, and frequency of wildfire ignitions." The proposed rescission contradicts this by authorizing new roads to mitigate wildfire risk. This is arbitrary and capricious disregard of agency's own science in violation of 5 U.S.C. § 706(2)(A). 2. FISCAL IRRATIONALITY: USFS deferred maintenance backlog exceeds $8.6-10.8 billion, with $6.4-6.9 billion tied to 370,000 miles of existing roads built 60+ years ago. Proposing new road construction while systematically underfunding existing infrastructure violates APA rational basis requirements. 3. PROCEDURAL INADEQUACY: Comment period is 53 days total (21 initial + 32 days). Original 2001 Roadless Rule: 129 days + 600 meetings. 2005 Bush rescission attempt: 182 days. This truncated process violates APA's requirement for meaningful public participation. 99% of initial public comments opposed rescission. 4. NEPA VIOLATION: DEIS fails to adequately analyze cumulative environmental impacts on 58.5 million acres, including degradation of municipal watersheds, loss of carbon sinks, habitat fragmentation, salmon spawning habitat destruction, and old-growth ecosystem loss. Fails hard-look review under Motor Vehicle Mfrs. v. State Farm, 463 U.S. 29 (1983). 5. ESA VIOLATION: Sweeping rescission across ranges of threatened/endangered species (marbled murrelet, northern spotted owl, salmon populations) without completed ESA Section 7 consultations violates 16 U.S.C. § 1536. Grounds for injunctive relief. 6. FEDERAL INDIAN LAW VIOLATION: Rescission breaches federal trust responsibility to tribes, violates Executive Order 13175 requiring government-to-government consultation, and endangers treaty-protected hunting, fishing, and gathering rights on ancestral lands. Industrial roadbuilding violates federal obligations to sovereign tribes. DEMAND I demand the Forest Service: - WITHDRAW the proposed rescission immediately - MAINTAIN the 2001 Roadless Rule in entirety - COMPLETE mandatory ESA Section 7 consultations - Provide 120-day comment period for any future rulemaking The 2001 Roadless Rule—enacted with broad bipartisan support and defended by federal courts—represents 25 years of successful policy protecting one-third of undeveloped National Forest System lands. This unlawful rescission will be challenged vigorously in federal court. A comprehensive detailed comment with full legal analysis is attached. Respectfully submitted, Lionel P. Trepanier Palm Desert, California 92211 lioneltrepanier@gmail.com October 6, 2026 --- [ATTACH FULL COMMENT DOCUMENT WITH COMPLETE ANALYSIS]

FORMAL PUBLIC COMMENT — PROPOSED RESCISSION OF 2001 ROADLESS RULE Docket Number: 2026-18648 October 6, 2026 TO THE U.S. FOREST SERVICE AND DEPARTMENT OF AGRICULTURE: I, Lionel P. Trepanier (lioneltrepanier@gmail.com, Palm Desert, CA 92211), submit this comment, behalf Utah Tar Sands Resistance, an organization with a long history of advocating for and physically protecting public lands in Utah, including in the National Forests. We write in strong opposition to rescission of the 2001 Roadless Area Conservation Rule. VIOLATION OF LAW This rescission violates the Administrative Procedure Act, National Environmental Policy Act, Endangered Species Act, and Federal Indian Law on multiple independent grounds: 1. APA VIOLATION—Arbitrary and Capricious: The agency's own Draft EIS states: "Road density is linked to human-caused wildfires, and as density of roads increases so does probability, number, and frequency of wildfire ignitions." The proposed rescission contradicts this by authorizing new roads to mitigate wildfire risk. This is arbitrary and capricious disregard of agency's own science in violation of 5 U.S.C. § 706(2)(A). 2. FISCAL IRRATIONALITY: USFS deferred maintenance backlog exceeds $8.6-10.8 billion, with $6.4-6.9 billion tied to 370,000 miles of existing roads built 60+ years ago. Proposing new road construction while systematically underfunding existing infrastructure violates APA rational basis requirements. 3. PROCEDURAL INADEQUACY: Comment period is 53 days total (21 initial + 32 days). Original 2001 Roadless Rule: 129 days + 600 meetings. 2005 Bush rescission attempt: 182 days. This truncated process violates APA's requirement for meaningful public participation. 99% of initial public comments opposed rescission. 4. NEPA VIOLATION: DEIS fails to adequately analyze cumulative environmental impacts on 58.5 million acres, including degradation of municipal watersheds, loss of carbon sinks, habitat fragmentation, salmon spawning habitat destruction, and old-growth ecosystem loss. Fails hard-look review under Motor Vehicle Mfrs. v. State Farm, 463 U.S. 29 (1983). 5. ESA VIOLATION: Sweeping rescission across ranges of threatened/endangered species (marbled murrelet, northern spotted owl, salmon populations) without completed ESA Section 7 consultations violates 16 U.S.C. § 1536. Grounds for injunctive relief. 6. FEDERAL INDIAN LAW VIOLATION: Rescission breaches federal trust responsibility to tribes, violates Executive Order 13175 requiring government-to-government consultation, and endangers treaty-protected hunting, fishing, and gathering rights on ancestral lands. Industrial roadbuilding violates federal obligations to sovereign tribes. DEMAND I demand the Forest Service: - WITHDRAW the proposed rescission immediately - MAINTAIN the 2001 Roadless Rule in entirety - COMPLETE mandatory ESA Section 7 consultations - Provide 120-day comment period for any future rulemaking The 2001 Roadless Rule—enacted with broad bipartisan support and defended by federal courts—represents 25 years of successful policy protecting one-third of undeveloped National Forest System lands. Respectfully submitted, Lionel P. Trepanier, personally and as Director Utah Tar Sands Resistance Palm Desert, California 92211 utahtarsandsresistance@gmail.com October 6, 2026 -

I am deeply concerned about the proposed rescission of the Roadless Rule. As someone who lives within Superior National Forest, I spend significant amounts of time hiking, camping, hunting, and fishing in Roadless Areas, both locally and on my journeys through western states. I am deeply concerned that rescinding the Roadless Rule will greatly impact my ability to hunt, fish, gather, travel by non-mechanical means, and recreate on my own public lands. If more of my Forests have roads through them, it greatly reduces the opportunities and access to the land- if there are more and more roads, I have to travel further and further to get away from them. I am additionally concerned about the issues that arise when people in vehicles have increased access to our Forests- significant increases in unintentional wildfires, significant increases in invasive species and aquatic invasive species, and degradation of soil and water quality. I hope the agency will do the right thing and not rescind the Roadless Rule. We have plenty of roads and plenty of access to our public lands as things are currently. The agency’s time and my tax payer dollars would be much better spent improving the hundreds of miles of National Forest roads and hundreds of NF buildings that are currently in disrepair. Additionally, I must point out: Unsourced National Wilderness Preservation System Acreage Figures (DEIS p. 195) The Draft EIS states, at page 195, in the Wilderness discussion under "Recreation Opportunities and Setting — Effects of Alternative 3 – Modified Rule": "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure is sourced. The sentence names no inventory, no dataset, and no date, and no source is supplied anywhere else in the document — each figure appears exactly once in the Draft EIS, in this one sentence. The only reference in the passage, Landres et al. 2015, appears three sentences later and is attached to a different proposition: the qualities the Forest Service and other wilderness-administering agencies read into "wilderness character." Nothing in the Draft EIS supports the acreages themselves. This is not a formality, because the quantity is not fixed. The Draft EIS states two sentences later that "Congress has the sole authority for designating additions to the National Wilderness Preservation System," and Congress has continued to exercise it. Without a named inventory and an effective date, a reader cannot tell whether 111.9 million and 36.7 million describe the system as it stands, the system as of some earlier compilation, or an internal calculation — nor whether the two figures were drawn from the same source as one another. The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on. The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A).

Re: Docket No. FS-2025-0001, RIN 0596–AD66: Special Areas; Roadless Area Conservation, Proposed Rule, 91 Fed. Reg. 53827 (Aug. 20, 2026) I oppose the proposed rescission of the 2001 Roadless Rule (removal of 36 C.F.R. part 294, subpart B). As a frequent visitor to the roadless areas of the George Washington and Jefferson National Forests in Virginia, and a very recent visitor to the roadless areas of White Mountain National Forest in New Hampshire, I urge the Department to withdraw the proposed rule, for these reasons: 1. The proposal is arbitrary and capricious under the APA (5 U.S.C. § 706(2)(A)). A rescission requires reasoned analysis, including why prior findings no longer hold and how reliance interests were weighed (Motor Vehicle Mfrs. Ass'n v. State Farm, 463 U.S. 29 (1983); DHS v. Regents, 591 U.S. 1 (2020); Organized Village of Kake v. USDA, 795 F.3d 956 (9th Cir. 2015) (en banc)). The Department invites comment on reliance interests (91 Fed. Reg. at 53830). For 25 years, communities, water providers, outfitters, and state wildlife agencies have relied on these protections. The stated goal of reducing "regulatory burden" is also unexplained: the Department concedes the rule imposes no requirements on small entities (id. at 53831), because it constrains only the agency. 2. The wildfire rationale does not support nationwide rescission. The Department grounds its rationale in changed conditions "especially in the Western United States" (id. at 53828), and concedes that greater access can increase human-caused ignitions (id. at 53829). The Rule already allows small-diameter cutting to reduce uncharacteristic wildfire risk (36 C.F.R. § 294.13(b)(1)(ii)) and roads for imminent fire threats (§ 294.12(b)(1)). The Department does not explain why Eastern forests such as the George Washington and Jefferson must lose protection. 3. The proposal is inconsistent with the forests' statutory purposes and the agency's own fiscal constraints. The Organic Act establishes national forests in part to secure "favorable conditions of water flows" (16 U.S.C. § 475). The Multiple-Use Sustained-Yield Act requires due consideration of watershed, wildlife, and recreation values (16 U.S.C. §§ 528–529). The Department identifies 18.2 million acres where plans would allow new permanent roads, while acknowledging a $6.9 billion deferred maintenance backlog for roads and bridges (91 Fed. Reg. at 53829). 4. The NEPA analysis is incomplete (42 U.S.C. § 4332(2)(C)). The Department acknowledges that later plan amendments "could increase the area where timber harvest and road construction would be allowed," yet treats those effects as beyond scope (id. at 53830). These are reasonably foreseeable effects of removing the national protections. The Department also failed to analyze a region-specific alternative, such as retaining protections in Eastern forests. USDA's 2005 repeal was invalidated for NEPA and ESA failures (California ex rel. Lockyer v. USDA, 575 F.3d 999 (9th Cir. 2009)), a history the Department itself recites (91 Fed. Reg. at 53827). 5. ESA consultation is required before any final rule (16 U.S.C. § 1536(a)(2)). The proposed rule makes no ESA determination among its regulatory certifications. It says only that future local decisions will remain subject to the ESA (id. at 53828). Removing nationwide protections across tens of millions of acres "may affect" listed species, including the Indiana bat and northern long-eared bat, whose ranges include the George Washington and Jefferson. Consultation is required on the rescission itself. The Department found tribal consultation warranted even where OMB guidance did not require it (id. at 53831). It should do the same under the ESA. 6. The Regulatory Flexibility Act certification is unsupported (5 U.S.C. § 605(b)). The Department acknowledges that outfitters, guides, and tour operators use these lands and estimates $6.1 million in annual recreation losses (91 Fed. Reg. at 53829–30). Yet it certifies no significant impact on small entities (id. at 53831). It is unconscionable for the department to ignore 25 years of success under the 2001 Roadless Rule and risk exacerbated wildfires and degraded water quality by rescinding the 2001 Roadless Rule. I urge the Department to retain the 2001 Roadless Rule and withdraw the proposed rescission. Thank you, Alec Shobe

Dear Secretary Rollins and Chief Schultz: I am writing to express my strong opposition to the recission of the 2001 Roadless Rule. The Roadless Rule is supported by peer reviewed research as well as the Forest Service's own analysis, and I want the land I love spending time to be protected in the future. I am concerned about fire risks associated with expanding roads and the potential impact on water quality, especially for major cities like Los Angeles that get most of their water from the Sierras. The DEIS's Own Tables 14 and 21 Contradict the Rationale's Forest-Health Causal Chain. The Rationale for the Proposed Rule states that the 2001 Roadless Rule “limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns” (DEIS p. 19). The comparative data the DEIS itself publishes contradict each step of that chain, and the FEIS must correct or withdraw the assertion. First, fire. Table 21 (DEIS p. 98) reports ignition density from the Interagency Fire Occurrence Reporting Module for 2014–2024: human-caused ignitions at 3.0 fires per million acres per year within potentially affected IRAs against 22.4 on other NFS lands, and natural ignitions at 8.5 against 16.8. The DEIS’s own text on that page explains why, finding that ignitions “increase in abundance with proximity to roads, supporting the notion that roads facilitate human access” and in turn more human-caused fires. The access the proposed rescission would restore is the variable the agency’s own data associate with a sevenfold higher human ignition rate. Second, the premise that the 2001 Rule produced a lack of active management. The DEIS reports that the Forest Service Activity Tracking System shows “an average of 500 acres per year of timber harvest and a total of 1.8 million acres of hazardous fuels reduction within IRAs” over the last decade (p. 15). On the same pages it concedes that “There is no national-level tracking of the review, approval, or implementation of 2001 Roadless Rule exceptions” (p. 14), and at p. 75 that while “Some of this annual mortality is observed within IRAs,” it is “not possible to characterize the mortality observed on IRAs on a national scale.” The agency thus states that it can measure neither the exceptions actually granted nor the roadless-specific mortality outcome, while asserting a causal relationship running from the first to the second. The rationale is therefore not merely unsupported; it is contradicted by the analysis printed in the same document. An explanation that runs counter to the evidence before the agency is arbitrary and capricious under 5 U.S.C. § 706(2)(A). Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002) (programmatic EIS may not pass over a risk the record permits it to analyze). I request a factual correction to the Rationale for the Proposed Rule under 7 CFR 1b.7(f)(2)(v), reconciling it with Table 14, Table 21, and the activity figures at pp. 14–15 — either by withdrawing the forest-health causal chain, or by stating, region by region and against those tables, where roadless designation is in fact associated with worse forest-health outcomes than active management. The correction cannot be deferred to project-level NEPA: the assertion is a rule-level justification, it appears in the rule’s rationale rather than in any effects analysis, and it is the premise against which alternatives were eliminated from detailed study as failing the purpose and need. If the FEIS retains the assertion, it should state which acres, in which regions, the tables are said to support it on, and where in the record the agency’s response is accounted for under 7 CFR 1b.7(f)(3). The Department should not rescind the 2001 Roadless Area Conservation Rule. CommentID: RLC-20261007-FAEAQ6

I implore you not to rescind the Roadless Rule. Having struggled with severe depression all my life, I cannot overstate how important these wild lands are to me. In my lows of loneliness and isolation, the one source of love, of community, of acceptance I could count on has been forests like the ones whose protections you consider removing. In an America without wild, roadless lands, where a person in pain can no longer retreat to the healing solitude of nature, I would have ended my life long ago. It breaks my heart to think of the harm rescission would do to the species who live on these lands, not to mention the people like me who depend on them for solace. The Rationale for the Proposed Rule states that the 2001 Roadless Rule “limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns” (DEIS p. 19). The comparative data the DEIS itself publishes contradict each step of that chain, and the FEIS must correct or withdraw the assertion. First, insect and disease. Table 14 (DEIS p. 75), “Percent of NFS forested acres at risk of tree mortality due to major forest insects and diseases, by land classification,” sets the actively managed lands — NFS ownerships outside designated areas — against inventoried roadless areas in the potentially affected environment. Northern Region: 50.4 percent outside designated areas against 34.2 percent in IRAs. Southwestern: 17.5 against 13.5. Pacific Southwest: 18.9 against 15.2. Pacific Northwest: 34.7 against 23.5. The DEIS states the conclusion in its own words on the same page: “the percent of forests at risk is similar or lower in potentially affected IRAs when compared to NFS forests outside of designated areas.” In the four western regions holding most of the roadless estate, the lands the rule has restricted from vegetation management carry less insect and disease risk than the lands it has not. Second, fire. Table 21 (DEIS p. 98) reports ignition density from the Interagency Fire Occurrence Reporting Module for 2014–2024: human-caused ignitions at 3.0 fires per million acres per year within potentially affected IRAs against 22.4 on other NFS lands, and natural ignitions at 8.5 against 16.8. The DEIS’s own text on that page explains why, finding that ignitions “increase in abundance with proximity to roads, supporting the notion that roads facilitate human access” and in turn more human-caused fires. The access the proposed rescission would restore is the variable the agency’s own data associate with a sevenfold higher human ignition rate. Third, the premise that the 2001 Rule produced a lack of active management. The DEIS reports that the Forest Service Activity Tracking System shows “an average of 500 acres per year of timber harvest and a total of 1.8 million acres of hazardous fuels reduction within IRAs” over the last decade (p. 15). On the same pages it concedes that “There is no national-level tracking of the review, approval, or implementation of 2001 Roadless Rule exceptions” (p. 14), and at p. 75 that while “Some of this annual mortality is observed within IRAs,” it is “not possible to characterize the mortality observed on IRAs on a national scale.” The agency thus states that it can measure neither the exceptions actually granted nor the roadless-specific mortality outcome, while asserting a causal relationship running from the first to the second. The rationale is therefore not merely unsupported; it is contradicted by the analysis printed in the same document. An explanation that runs counter to the evidence before the agency is arbitrary and capricious under 5 U.S.C. § 706(2)(A). Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002) (programmatic EIS may not pass over a risk the record permits it to analyze). I request a factual correction to the Rationale for the Proposed Rule under 7 CFR 1b.7(f)(2)(v), reconciling it with Table 14, Table 21, and the activity figures at pp. 14–15 — either by withdrawing the forest-health causal chain, or by stating, region by region and against those tables, where roadless designation is in fact associated with worse forest-health outcomes than active management. The correction cannot be deferred to project-level NEPA: the assertion is a rule-level justification, it appears in the rule’s rationale rather than in any effects analysis, and it is the premise against which alternatives were eliminated from detailed study as failing the purpose and need. If the FEIS retains the assertion, it should state which acres, in which regions, the tables are said to support it on, and where in the record the agency’s response is accounted for under 7 CFR 1b.7(f)(3).

Please keep the amazing piece of policy, the roadless rule, live and enforced. America is its land, and it's people. I am connected to desolation wilderness in the Tahoe basin. Increased devistation will only result in a less secure climate, resulting in more wildfires and harm done to innocent families that garner no benefit from the destruction and increase to shareholder value. My name is Nathaniel Griffin and I will only suffer if this rule is removed. We must encourage sustainable practices, not allow devastation in our birthright. Thank you Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. The DEIS also quantifies the differential, and the relevant figure is not the one most often quoted. Table 18 (p. 95) reports all-cause ignition density of 42 fires per million acres per year on other NFS lands against 12 in potentially affected IRAs. Table 21 (p. 98) decomposes that figure by cause: human-caused ignition density is 22.4 against 3.0 — a factor of 7.5 — while the natural-ignition rates are far closer at 16.8 against 8.5. The differential the DEIS attributes to roads is therefore the human-caused component, and it is more than twice the size the all-cause comparison suggests. Notwithstanding these findings, the DEIS concludes at p. 113 that "the net impact of new roads on fire occurrence is likely small or insignificant, given the potential for improved response times and increased initial attack success." No source is cited for that conclusion, and no estimate of the ignition increase appears anywhere in the effects analysis for either action alternative. Its two supporting assumptions are unquantified and uncommitted. At p. 109 the DEIS reasons that "not all roads constructed under alternative 2 would be open for public access. Therefore, increased human ignitions do not necessarily follow from increased road construction." At p. 113 it states that "public access to roads constructed or improved under alternatives 2 and 3 can be limited to minimize fire hazard in high-risk areas." Neither alternative commits to any level of access restriction, no proportion of closed roads is estimated, no basis is given for expecting any particular proportion, and the rescission itself transfers that decision to local responsible officials. The analysis thus supplies the mitigating assumption while the rule removes the national requirement that would deliver it. The DEIS states the method for closing this gap and does not perform it. At p. 109: "As discussed in Wildfire Occurrence, past fire occurrence information on NFS lands, inventoried roadless areas, and wilderness can be used to evaluate the potential effects of new road construction." The necessary input is already in the document. Figure 15 (p. 98), "Density of reported ignitions by distance to roads and cause within the potentially affected IRAs," is the ignition-to-road-distance gradient measured inside the affected area itself. Figure 15 appears in the body of the DEIS once, as that caption. No text discusses it and no effects analysis applies it. Because the DEIS announces this analysis, presents the data for it, and then substitutes an uncited qualitative conclusion that runs against its own cited sources, its effects finding for wildfire occurrence is not supported by the record before the agency. An explanation that runs counter to the evidence before the agency does not satisfy reasoned decisionmaking. Motor Vehicle Mfrs. Ass'n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002) (programmatic EIS may not defer analysis of an effect that is properly assessed at the programmatic scale). This is a challenge to the sufficiency of the agency's explanation under 5 U.S.C. § 706(2)(A), not to the scope or depth of analysis the agency selected. I request that the Forest Service supplement the wildfire occurrence effects analysis under 7 CFR 1b.7(f)(2)(iii) to: (1) apply the Figure 15 ignition-density-by-road-distance relationship, together with the human-caused ignition rates in Table 21, to estimate the change in ignition density within potentially affected IRAs under alternatives 2 and 3 at a stated level of new road construction; (2) state the proportion of ne

I am writing in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR Part 294, Subpart B; Docket FS-2025-0001). Rescinding blanket protections across 58.5 million acres of Inventoried Roadless Areas (IRAs) threatens headwater drinking supplies, critical fish and wildlife habitat, and vital backcountry recreation, while failing to meet basic legal requirements. First, the proposal violates the Administrative Procedure Act (5 U.S.C. § 706(2)(A)). Under Motor Vehicle Mfrs. Ass'n v. State Farm, 463 U.S. 29 (1983), an agency reversing course must provide a reasoned explanation supported by empirical facts. When the Tenth Circuit upheld the 2001 Rule in Wyoming v. USDA, 661 F.3d 1209 (10th Cir. 2011), it recognized the agency’s extensive record showing that local, forest-by-forest planning had demonstrably failed to prevent the piecemeal degradation of roadless areas. Citing political directives for timber extraction and "local flexibility" does not overcome this established record. Second, the rescission ignores the National Environmental Policy Act (NEPA, 42 U.S.C. § 4332). In California ex rel. Lockyer v. USDA, 575 F.3d 999 (9th Cir. 2009), the Ninth Circuit struck down the 2005 State Petitions Rule because the agency failed to conduct a programmatic "hard look" at the cumulative environmental impacts of removing national protections. Shifting management to localized decisions does not excuse the Forest Service from analyzing cumulative fragmentation, erosion, and biodiversity loss. Third, using wildfire prevention as a justification is fundamentally flawed. The 2001 Rule already allows fuel reduction and small-diameter timber removal to reduce wildfire risks near communities (36 CFR § 294.13(b)(1)). Roads increase human ignitions and fire risk, and building new roads into remote backcountry will only exacerbate the agency’s multibillion-dollar deferred road maintenance backlog, contradicting sustainable management mandates under the Multiple-Use Sustained-Yield Act of 1960 (MUSYA). Finally, roadless areas serve as essential strongholds for species protected under the Endangered Species Act (ESA) and fulfill diversity requirements under the National Forest Management Act (NFMA, 16 U.S.C. § 1604(g)(3)(B)). Lifting nationwide prohibitions will fracture migration corridors and imperil sensitive populations. The Forest Service must withdraw this proposal and maintain the established protections of the 2001 Roadless Rule.

Let's not give away the future “health” of our natural lands by rescinding the Roadless Rule. Large areas need to remain safe from human pollution and chemicals (logging and mining). The environment of western Washington has already been greatly affected by human beings. There's now a strange absence of mosquitoes at popular campgrounds. Populations of frogs and salamanders have greatly decreased. These are signals we can't ignore. We need to keep Alternative 1, the Roadless Rule. Alternative 2 has many flaws. For one thing, there is an Unquantified Magnitude Finding on Stored-Carbon Loss Under Alternative 2. The Draft EIS quantifies the carbon stock at issue and then declines to quantify the effect of the action on it, resting its finding on a comparison it never performs. At p. 74 the Draft EIS states: "Birdsey et al. (2025) estimate the IRAs contain about 5 percent of the stored forest carbon in the coterminous United States (0.9B Mg C)." At p. 87, under "Implications for Forest Vegetation, Health, and Carbon," the Draft EIS concedes the mechanism: "Under alternative 2, where future road construction, timber harvest, or non-commercial forest management remove vegetation, there would be a loss of stored carbon. Areas affected by permanent tree removal activities, such as permanent road construction, would lose capacity for carbon sequestration." It then disposes of the magnitude in a single sentence: "Given forest management objectives, these areas would be small compared to the overall carbon within the forested landscape within roadless areas." That is a quantitative comparison with only one term supplied. The Draft EIS gives the denominator - 0.9 billion Mg C - and never estimates the numerator. It does not state how many acres of the 44.7-million-acre potentially affected environment are expected to be roaded, harvested, or otherwise entered under alternative 2, what carbon density those acres carry, or over what period the loss and any recovery would occur. The finding that the loss would be "small" therefore rests on no disclosed quantity at any scale, and a reader cannot tell whether the agency is describing a fraction of a percent or a tenth of the stock it has just quantified. The Draft EIS's own source also undercuts the recovery assumption offered in mitigation. I request that the Forest Service supplement the forest vegetation and carbon analysis to disclose a quantified or bounded estimate of stored-carbon loss and foregone sequestration under each alternative, using the acreage and operability data already in Table 16 and the stock estimate already at p. 74; and, if the agency retains the finding that affected areas would be "small compared to the overall carbon within the forested landscape within roadless areas," that it disclose the quantities that comparison rests on. If no such estimate can be produced, the Draft EIS should state on the record why data the agency itself compiled will not support one. An agency may not rest a finding of no material effect on a magnitude comparison whose terms it declines to supply when it holds the data to supply them. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. 706(2)(A). We need to keep Alternative 1 and make it permanent. It's vital to preserve our natural areas now. The Roadless Rule is the major baseline to keep our nation's land healthy.

Unsourced National Wilderness Preservation System Acreage Figures (DEIS p. 195) The Draft EIS states, at page 195, in the Wilderness discussion under "Recreation Opportunities and Setting — Effects of Alternative 3 – Modified Rule": "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure is sourced. The sentence names no inventory, no dataset, and no date, and no source is supplied anywhere else in the document — each figure appears exactly once in the Draft EIS, in this one sentence. The only reference in the passage, Landres et al. 2015, appears three sentences later and is attached to a different proposition: the qualities the Forest Service and other wilderness-administering agencies read into "wilderness character." Nothing in the Draft EIS supports the acreages themselves. This is not a formality, because the quantity is not fixed. The Draft EIS states two sentences later that "Congress has the sole authority for designating additions to the National Wilderness Preservation System," and Congress has continued to exercise it. Without a named inventory and an effective date, a reader cannot tell whether 111.9 million and 36.7 million describe the system as it stands, the system as of some earlier compilation, or an internal calculation — nor whether the two figures were drawn from the same source as one another. The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on. The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A).

My family has long enjoyed the beauty and calm of the lands that will be harmed by creating more roads into our public lands. Please preserve what remains for our children. I have enjoyed birding for decades and want to preserve the environment for migratory birds. Protect the migratory bird corridors so we can enjoy their work in pollination and insect control. This change will reduce numbers of birds across America. The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on. The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A).

My family runs a chapter of KAMO, Kids And Mentors Outdoors in Wisconsin, we teach and show a love of all things outdoors to our youth, these public Roadless areas are our youths inheritance that we the People (Taxpayers) have paid for and continue to pay for to this day, most of us are happy to pay this so we have free access to these areas. In Wisconsin by us the DNR had a tree sale and it took over 7 years to hear an Owl again, theres better ways to take care of these lands more naturally. It's an asset to this country and it'll hurt our tourism dollars. We know the playbook, it's always for the greater good or for your safety but it's really to line someones pocket, not this time these public lands are a critical place in our country. LEAVE THE ROADLESS RULE IN PLACE!! Unsourced National Wilderness Preservation System Acreage Figures (DEIS p. 195) The Draft EIS states, at page 195, in the Wilderness discussion under "Recreation Opportunities and Setting — Effects of Alternative 3 – Modified Rule": "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure is sourced. The sentence names no inventory, no dataset, and no date, and no source is supplied anywhere else in the document — each figure appears exactly once in the Draft EIS, in this one sentence. The only reference in the passage, Landres et al. 2015, appears three sentences later and is attached to a different proposition: the qualities the Forest Service and other wilderness-administering agencies read into "wilderness character." Nothing in the Draft EIS supports the acreages themselves. This is not a formality, because the quantity is not fixed. The Draft EIS states two sentences later that "Congress has the sole authority for designating additions to the National Wilderness Preservation System," and Congress has continued to exercise it. Without a named inventory and an effective date, a reader cannot tell whether 111.9 million and 36.7 million describe the system as it stands, the system as of some earlier compilation, or an internal calculation — nor whether the two figures were drawn from the same source as one another. The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on. The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A).

My family runs a chapter of KAMO, Kids And Mentors Outdoors in Wisconsin, we teach and show a love of all things outdoors to our youth, these public Roadless areas are our youths inheritance that we the People (Taxpayers) have paid for and continue to pay for to this day, most of us are happy to pay this so we have free access to these areas. In Wisconsin by us the DNR had a tree sale and it took over 7 years to hear an Owl again, theres better ways to take care of these lands more naturally. It's an asset to this country and it'll hurt our tourism dollars. We know the playbook, it's always for the greater good or for your safety but it's really to line someones pocket, not this time these public lands are a critical place in our country. LEAVE THE ROADLESS RULE IN PLACE!! Unsourced National Wilderness Preservation System Acreage Figures (DEIS p. 195) The Draft EIS states, at page 195, in the Wilderness discussion under "Recreation Opportunities and Setting — Effects of Alternative 3 – Modified Rule": "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure is sourced. The sentence names no inventory, no dataset, and no date, and no source is supplied anywhere else in the document — each figure appears exactly once in the Draft EIS, in this one sentence. The only reference in the passage, Landres et al. 2015, appears three sentences later and is attached to a different proposition: the qualities the Forest Service and other wilderness-administering agencies read into "wilderness character." Nothing in the Draft EIS supports the acreages themselves. This is not a formality, because the quantity is not fixed. The Draft EIS states two sentences later that "Congress has the sole authority for designating additions to the National Wilderness Preservation System," and Congress has continued to exercise it. Without a named inventory and an effective date, a reader cannot tell whether 111.9 million and 36.7 million describe the system as it stands, the system as of some earlier compilation, or an internal calculation — nor whether the two figures were drawn from the same source as one another. The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on. The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A). CommentID: RLC-20261005-NIR1G6

I support keeping our forests and wildlife areas roadless. Do not recind protections that are in place currently. I hike in the thousands of acres in northern Wisconsin. My mental and physical health would be degraded if these places were spoiled by roads, and or other developments. These protected places are important for the overall well-being of our communities. I travel to the forest communities from 300 miles away. I spend money in these towns and if these wild areas were degraded, I would not spend tourism dollars there. Their livelihoods would suffer. Please leave our wild places wild and roadless Unsourced FY2024 Recreation Visitation Figure and Unresolved NVUM Citation at Draft EIS p. 220 At page 220 of the Draft EIS, under "Recreation Opportunities and Setting - Effects of Alternative 3 - Modified Rule - Economic Activity from Recreation in Roadless Areas," the Draft EIS states: "The 193 million acres administered by the Forest Service received approximately 164 million recreation visits in FY2024." That sentence carries no citation, and no citation anywhere in the paragraph supplies one. The paragraph's citations are attached to other propositions. White et al. 2016 is attached to the sentence immediately preceding the figure - "Some communities located around Federal recreation lands have a high dependence on economic inputs from recreation visitor spending and may experience negative economic conditions if visitation declines or visitor spending patterns change (White et al. 2016)" - which is a statement about community dependence, not about visitation counts. USDA Forest Service 2025a (National Forest and Grassland Economic Contributions, Forest Service Publication FS-1251) is attached two sentences after the figure, to "Visitor spending in FY2023 contributed approximately $16.2 billion to U.S. GDP and supported about 167,000 jobs, both full-time and part-time." Every other statistic in that paragraph is FY2023 and is drawn from that FY2023 source. The FY2024 visitation count is the only FY2024 datum in the paragraph, and a source cited for FY2023 spending and GDP cannot supply an FY2024 visit count. The same sentence appears at page 16 of the Economic Analysis, where the sentence order is different - the figure appears first and the White et al. 2016 citation two sentences after it - which confirms that no source is attached to the figure in either document. The Draft EIS also cites the National Visitor Use Monitoring program at page 220 as "(USDA Forest Service 2026a)." The string "Forest Service 2026" appears exactly once in Volume I, at that in-text citation. The References Cited section at pages 249-285 contains no entry for USDA Forest Service 2026a; its only National Visitor Use Monitoring entry reads "U.S. Department of Agriculture, Forest Service. 2024. Forest Service National Visitor Use Monitoring Data Dashboards." The Draft EIS therefore relies on an unidentified source for the one program capable of producing a national visitation figure, and the public cannot review the data the agency used. These are not questions of citation form. The FY2024 visitation figure is the quantitative foundation of the recreation-economics discussion at pages 220-222, which the Draft EIS uses to characterize the visitor spending and employment potentially affected by the rescission. A quantity asserted with no source in the record is not a fact found, and under 5 U.S.C. 706(2)(A) and Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983), the agency must articulate a rational connection between the facts found and the choice made. It cannot do so on a figure the record does not support. Because this concerns compliance with applicable law, the information is substantive under 7 CFR 1b.11(a)(53) and the issue cannot be certified as comparatively not of a substantive nature under 7 CFR 1b.7(j). I request two factual corrections under 7 CFR 1b.7(f)(2)(v), each of which the agency should account for by citation under 7 CFR 1b.7(f)(3): 1. Supply the source and data year for the FY2024 visitation estimate at Draft EIS page 220 and Economic Analysis page 16, or remove the figure from both documents. If the source is the National Visitor Use Monitoring program, identify the specific NVUM release and its publication date. 2. Add a complete References Cited entry for "USDA Forest Service 2026a," or correct the in-text citation at page 220 to the source actually relied upon. Because the same unsupported figure carries the recreation baseline in the Economic Analysis that supports the proposed rule, these corrections are owed both in the Final EIS and in the final rule's explanation of the economic effects on which it relies.

I recently retired and plan to spend the next few years exploring our national parks. Rescinding the roadless rule will open pristine lands to motorized vehicles which will create pollution. Leave our pristine roadless places alone so the beauty in our parks will be preserved for my (and other’s) arrival!! Uncited National Forest System Wilderness Acreage Relied On for the Alternative 3 Recreation Substitution Finding The Draft EIS states, at page 195, under *Recreation Opportunities and Setting — Effects of Alternative 3 – Modified Rule — Wilderness*: "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure carries a citation, and the National Forest System sub-total is the one this comment concerns. The only scientific citation anywhere in that paragraph is Landres et al. 2015, which appears three sentences later and is attached to a different proposition — the five qualities the Forest Service and other wilderness-administering agencies read into "wilderness character" under Section 2(a) of the Wilderness Act. It is not offered in support of either acreage. The next citation in the passage, 36 CFR 219.7(c)(2) at page 196, is attached to the plan-level identification of recommended wilderness. Between them the Draft EIS also states that National Forest System wilderness areas "receive about 13 million visits each year or 8 percent of the visits to all lands in national forests," and that figure is uncited as well. The Draft EIS does not identify the inventory the 36.7-million-acre figure was drawn from, or the date as of which it was current. I do not contend the figure is numerically wrong. I contend that a reader of this Draft EIS cannot determine what it rests on, and that this matters because the Draft EIS puts the figure to work in its effects analysis rather than offering it as background. The same paragraph reasons that "Congressionally designated wilderness within the National Forest System offers many similar recreation opportunities as roadless areas (except for motorized and mechanized trail activities)," and the analysis of Alternative 3 relies on that comparison to treat the non-motorized recreation opportunities now afforded by inventoried roadless areas as remaining available on other National Forest System lands after rescission. The 36.7-million-acre figure is the quantity that makes that substitution appear sufficient: it is the measure of how much comparable land the agency says remains. If the figure is drawn from an inventory that predates subsequent designations, boundary adjustments, or transfers, or if it counts acreage the agency does not in fact manage for the qualities it invokes, then the extent of substitute opportunity is overstated and the effect of rescission on non-motorized recreation in inventoried roadless areas is correspondingly understated. Neither the reader nor the decisionmaker can test that, because the source is not given. This states an issue within the meaning of 7 CFR 1b.11(a)(23): rescission of the 2001 Roadless Rule is the action, the availability of comparable non-motorized recreation opportunity on other National Forest System lands is the reasonably foreseeable effect, and the National Forest System wilderness acreage is the sole quantity the Draft EIS offers to measure that effect. An unsourced quantity cannot support the finding it is used to support. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS name the source of the 36.7-million-acre National Forest System wilderness figure and the date as of which that source was current, and state, where the effects analysis relies on the figure, how it supports the finding that designated wilderness provides recreation opportunity comparable to inventoried roadless areas. I do not ask the agency to adopt any particular database; I ask that whatever source it used be identified, so that the figure is traceable. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. This is a single request and I join no other to it. If the agency's position is that no source can be identified, it should say so expressly and state the basis on which the figure was derived, so that the record shows what the Final EIS's account of the wilderness estate rests on. The provenance of a quantity the effects analysis relies upon is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable laws within the meaning of 7 CFR 1b.11(a)(53). An agency must articulate a satisfactory explanation for its action, including a rational connection between the facts found and the choice made, supported by evidence in the record. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A).

I spent college up in the western NC mountains and their beauty match no other, destroying these lands for development and logging would be detrimental to tourism and the environment. I am an archaeologist who loves to hike in nature and protect lands. Land is already being destroyed and developed on in many other places in the state, including where I live now. To see my refuge be affected by greedy corporations who want land and money hurts my heart greatly. Protect these lands, the diversity they hold and the emotional significance to millions of people. I recently went hiking in the Linville Gorge and visited the falls, it was amazingly beautiful and refreshing. After many trails were affected by Hurricane Helene and have only recently been reopened the revenue lost for those years will only grow if land is taken. I first hiked in the Appalachian mountains and I wish to take my kids there for their first hikes. I need them to experience the beauty of one of the oldest mountain ranges in the world in its natural state not in capitalistic infrastructure the exudes greed. Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Mineral extraction, oil and gas development, and associated infrastructure permanently industrialize otherwise undeveloped landscapes. Roadless areas store carbon, buffer temperature extremes, and provide intact refugia where species can shift in response to a warming climate. DEIS Regional Carbon Accounting Omits a Forest Service Region and Drops the Source's Own Attribution of the National Forest System Sink The Draft EIS's National Forest System carbon baseline misstates the source it cites, in two respects that appear within a single sentence and that the source itself resolves. At Volume I, page 74 (Alternative 3 – Modified Roadless Rule/IRA Boundaries, Potentially Affected Environment, Forest Vegetation), the Draft EIS states: "In 2021, forested lands within the national forest system sequestered 43.5 million metric tons (MMT) CO2, which follows national trends of increasing forest biomass in recent decades, however forests in the drier and more fire prone Intermountain, Rocky Mountain, Northern, and Southwestern Forest Service regions had net carbon loss (31.5 MMT CO2) while the remaining regions had a net carbon increase, sequestering 63.5 MMT CO2 (Domke et al. 2023)." First, the sentence's components do not produce its own total. A net loss of 31.5 MMT set against a net gain of 63.5 MMT yields a net sink of 32.0 MMT, not the 43.5 MMT the same sentence reports. The source shows where the discrepancy comes from. Domke et al. 2023, table 3 ("Carbon stock changes (net flux) from forest land remaining forest land within the National Forest System (NFS) by NFS region and year (MMT CO2 Eq.)"), gives 2021 net flux for all nine National Forest System regions. The four regions the Draft EIS names as net-loss regions are the four with positive values — Intermountain 11.5, Rocky Mountain 12.2, Southwestern 6.9, and Northern 0.9 — which sum to 31.5, the figure the Draft EIS reports correctly. The remaining five regions are Alaska (4.0), Eastern (11.5), Pacific Northwest (28.3), Pacific Southwest (5.7), and Southern (25.5), which sum to 75.0 MMT of net uptake, not 63.5. The Draft EIS's 63.5 is 75.0 less the Eastern Region's 11.5: the Eastern Region has been dropped from the uptake side while the total continues to include it. Restoring it reconciles the sentence, because 75.0 less 31.5 is 43.5, which is table 3's own net line for 2021. Both are factual corrections within the meaning of 7 CFR 1b.7(f)(2)(v), and under 7 CFR 1b.7(f)(3) the agency should cite where in the Final EIS each correction is accounted for. The issue is substantive under 7 CFR 1b.11(a)(53) because it bears on compliance with applicable laws: an agency may not rest an environmental analysis on a characterization that the record it chose to rely on contradicts. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A). Domke et al. 2023 is a Forest Service publication cited in the Draft EIS's own literature cited section, so these corrections require nothing of the agency beyond agreement with its own source.

Hello, I am writing in support of the roadless rule, which protects and promotes both wildlife and recreation for our national forests. I live near several wilderness areas in western North Carolina and enjoy the solitude and wild nature of these areas for hiking, camping, trail, running, and want to preserve this for generations to come. The road this rule was created to ensure longevity for our forests for wildlife and people. Let’s keep it that way! Unsourced National Wilderness Preservation System Acreage Figures (DEIS p. 195) The Draft EIS states, at page 195, in the Wilderness discussion under "Recreation Opportunities and Setting — Effects of Alternative 3 – Modified Rule": "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure is sourced. The sentence names no inventory, no dataset, and no date, and no source is supplied anywhere else in the document — each figure appears exactly once in the Draft EIS, in this one sentence. The only reference in the passage, Landres et al. 2015, appears three sentences later and is attached to a different proposition: the qualities the Forest Service and other wilderness-administering agencies read into "wilderness character." Nothing in the Draft EIS supports the acreages themselves. This is not a formality, because the quantity is not fixed. The Draft EIS states two sentences later that "Congress has the sole authority for designating additions to the National Wilderness Preservation System," and Congress has continued to exercise it. Without a named inventory and an effective date, a reader cannot tell whether 111.9 million and 36.7 million describe the system as it stands, the system as of some earlier compilation, or an internal calculation — nor whether the two figures were drawn from the same source as one another. The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on. The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A).

Here is a revised, high-impact version that preserves all your facts, statutory references, data, citations, and personal connection while paring down the character count significantly. Dear Chief Tom Schultz: As someone who has spent a career weighing irreversible decisions against reversible ones, I take this rescission seriously. I love showing my children what makes the USA unique—our variety and quantity of wild nature. When these areas lose their wild character and face greater fire risk due to roads and added access, they lose their inherent value. Regarding Blue Lake in the Gifford Pinchot National Forest, Washington: Forest plans provide the legal framework for managing national forests under the National Forest Management Act of 1976. The Roadless Rule supplements these plans by adding a uniform layer of protection against road construction and commercial timber harvest across all inventoried roadless areas (IRAs) (USDA Forest Service, 2001, 66 FR 3244). Rescinding the Roadless Rule would open Blue Lake to road construction and ground disturbance, making specific comments on this area necessary. It is wrong and shortsighted. The DEIS’s Own Tables 14 and 21 Contradict the Forest-Health Causal Chain The Rationale for the Proposed Rule asserts that the 2001 Roadless Rule limited active management, contributing to forest health challenges (DEIS p. 19). The DEIS’s own data directly contradict this logic: Insect and Disease Risk: Table 14 (p. 75) shows that the percentage of forested acres at risk of mortality from insects and disease is lower in IRAs than in actively managed NFS lands outside designated areas across key western regions: Northern (34.2% in IRAs vs. 50.4% outside), Southwestern (13.5% vs. 17.5%), Pacific Southwest (15.2% vs. 18.9%), and Pacific Northwest (23.5% vs. 34.7%). As the DEIS notes (p. 75), risk is "similar or lower in potentially affected IRAs." Fire Risk and Road Access: Table 21 (p. 98, 2014–2024 data) shows human-caused ignitions are nearly eight times higher outside IRAs (22.4 fires per million acres/year) than within IRAs (3.0), while natural ignitions are also higher outside (16.8 vs. 8.5). The DEIS explicitly notes that ignitions "increase in abundance with proximity to roads." Restoring road access introduces the very variable associated with a vastly higher human ignition rate. Lack of Active Management Premise: The DEIS records an average of 500 acres/year of timber harvest and 1.8 million acres of hazardous fuels reduction within IRAs over the last decade (p. 15). Yet the agency concedes there is "no national-level tracking of the review, approval, or implementation of 2001 Roadless Rule exceptions" (p. 14) and that mortality on IRAs cannot be characterized nationally (p. 75). Asserting a causal link while failing to track exceptions or mortality outcomes is unsupported. An explanation that runs counter to the evidence before the agency is arbitrary and capricious under 5 U.S.C. § 706(2)(A) (Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Kern v. BLM, 284 F.3d 1062 (9th Cir. 2002)). I request a formal factual correction under 7 CFR 1b.7(f)(2)(v) reconciling the Rationale with Tables 14, 21, and pp. 14–15—either by withdrawing the forest-health causal chain or detailing region-by-region where IRAs suffer worse health outcomes than actively managed lands. This cannot be deferred to project-level NEPA, as it forms the rule-level premise used to eliminate alternatives. If retained in the FEIS, state which acres and regions support this assertion and account for the response under 7 CFR 1b.7(f)(3). Please make the right choice, Laura Gahan

The draft EIS states, at page 17 and again at page 304, that "[o]f the comment letters received, approximately 99 percent were generally opposed to the proposed rule recission, while approximately 1 percent were generally in support." The same paragraph at page 17 states that "[m]ore than 90 percent of the letters received contained brief sentiments or opinions on the proposed action." Both are quantified findings about the notice of intent comment record. Neither carries a citation, and the draft EIS discloses no criteria by which any letter was assigned to any of those categories. The document says the coding occurred. Appendix 3 states at page 305 that "[a]ll NOI comments were reviewed, coded, and analyzed to develop the below overarching themes, concerns, and recommendations." That is the only appearance of the word "coded" in the draft EIS. What accompanies it is a list of four things the agency did in response — modifying the proposed action or developing alternatives, using information to inform the analysis, making factual corrections, and considering but making no change — and, at footnote 72, the definition of "substantive" the agency applied in deciding which comments to summarize. Those disclose how comments were sorted for theme and for response. Neither discloses how a letter was determined to be "generally opposed" or "generally in support," how a letter expressing mixed views was assigned, how form letters and letter-generator submissions were treated, or how petition signatures bear on the percentages, when the same paragraph reports over 220,000 letters representing over 625,000 submissions. This bears on the analysis, not only on the summary. The draft EIS states at page 17 that "[c]omments received in response to the NOI were used to inform the range of alternatives and environmental impact analyses," and Appendix 3 states that the coded comments produced the themes, concerns, and recommendations the agency responded to. The sort therefore determined which concerns reached the alternatives development described in Chapter 2. A quantified characterization of the comment record that the record itself cannot reproduce is not merely a descriptive summary; it is an input to the range of alternatives, and the draft EIS says so. I request a factual correction under 7 CFR 1b.7(f)(2)(v). The final EIS should either support the 99 percent, 1 percent, and 90 percent figures by stating the criteria used to assign a letter to each category — including the treatment of mixed and ambiguous letters, form letters, and petition signatures — and identifying where that determination is documented in the proposal record, or qualify those figures to what the record supports. Under 7 CFR 1b.7(f)(3), the final EIS should cite where that correction is accounted for. This is not a request that the agency perform new work; it is a request that a number the agency chose to publish be supported by the record that carries it, or else be stated as the approximation the record can support. Separately, and addressed to the final rule rather than to the environmental impact statement: if the preamble relies on any characterization of the volume or direction of public comment in explaining the departure from the 2001 Roadless Area Conservation Rule, that characterization must rest on something the record shows, and the agency must articulate a rational connection between the facts found and the choice made. Motor Vehicle Mfrs. Ass'n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. 706(2)(A). A response to this point in the final EIS comment appendix does not answer it in the preamble.

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.