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Re: RIN 0596-AD66, Docket No. FS-2025-0001 — Proposed Rescission of the 2001 Roadless Area Conservation Rule I strongly oppose the proposed rescission and ask the Department to adopt the No Action alternative. I live in Santa Cruz County, California, and have worked in mortgage lending on the Central Coast for 35+ years. I know what wildfire does to communities and home values, and I take the Department's concerns seriously. I have also supported the National Forest Foundation, the Forest Service's chartered partner; my contributions funded nearly 30,000 trees on national forest land. That taught me how slowly a damaged forest recovers, and that protecting intact forest is cheaper than restoring it. Rescission is not needed to address wildfire, and what it gives up cannot be restored. 1. The loss is permanent; the benefit, by the Department's own account, is small. The preamble says management opportunities "would be modest and localized." The projected timber gain (5 to 10 percent more sawtimber; $5.2 to $11.4 million per year) assumes harvest across all 4.8 million operable acres, which the Department calls "unlikely." Against that, it estimates recreation losses of $6.1 million per year and total effects that "could exceed $100 million." Roads are rarely undone, and the agency already carries a $6.9 billion road and bridge maintenance backlog. Once roaded, intact watersheds, habitat, and quiet backcountry do not return. Trading permanent loss for modest, uncertain gain is poor policy. 2. The 2001 Rule already permits the wildfire work the Department cites. The preamble says the prohibitions "removed important management tools." But the Rule expressly allows removal of "generally small diameter timber" to "reduce the risk of uncharacteristic wildfire effects" (36 CFR 294.13(b)(1)(ii)) and road construction "needed to protect public health and safety in cases of an imminent threat of flood, fire, or other catastrophic event" (§ 294.12(b)(1)). The real complaint is that these exceptions were used in a "limited and inconsistent" way due to reviews and approvals. That is an administrative problem with an administrative fix, not grounds to strip protection from 58.5 million acres. By the Department's figures, the wildland-urban interface covers only 24 percent (9.8 million acres) of the affected lands; three-quarters lies away from the communities the rationale is meant to protect. 3. New roads would add to wildfire risk. Roads bring people, and people start fires. A national study of 1992–2012 records found humans ignited 84 percent of U.S. wildfires and nearly tripled the fire season (Balch et al., PNAS, 2017). The preamble concedes access "can increase human-caused ignition potential." Roads can also open private inholdings to development, as the Alaska petition requests; each new home at the forest edge adds ignition sources, fragments habitat, and adds to what firefighters must defend. 4. Rescission removes the national floor and leaves future development unanalyzed. The proposal authorizes no projects, yet admits later plan amendments "could increase the area where timber harvest and road construction would be allowed," with impacts "beyond those summarized above," and treats them as out of scope. It also adds flexibility for oil, gas, and coal leasing. The analysis measures near-term effects under today's plans while removing the only national limit on tomorrow's. The cumulative effect across 100-plus national forests is not evaluated. 5. Public input would fragment. These lands belong to all Americans. The 2001 Rule followed a national process with about 430 public meetings (66 FR 3244). Under rescission, each area would be decided forest by forest; a Californian would have to follow dozens of proceedings to have the voice available today in one. Tribes agree, citing "the unsustainable burden of project-level review." The process is also rushed: 21 days of comment on the notice of intent, 30 (since extended to 45) on a decision affecting 58.5 million acres, and only 29 of 64 requested Tribal consultations held. Recommended alternative Retain the 2001 Rule. If fuel-reduction work is slowed, fix that narrowly: (a) streamline approval of the existing exceptions within the wildland-urban interface, e.g., by delegating to regional foresters with fixed deadlines; (b) keep using the state petition process (5 U.S.C. 553(e); 7 CFR 1.28), as Idaho and Colorado did. This serves the Department's objectives without stripping protection from the three-quarters of affected land outside the interface. I recognize the needs of timber-dependent communities and the danger of wildfire, but the Department's own numbers show modest, uncertain gains against permanent loss. I respectfully urge withdrawal of this proposal. In closing, this land is largely as nature created it. Whatever one's beliefs about its origin, humans must leave some lands wild and untouched. Respectfully submitted, Forrest Cambell

Dear Secretary Rollins, On behalf of the Affiliated Tribes of Northwest Indians (ATNI), please find enclosed Resolution 2026-054 adopted by the ATNI membership at the 2026 Annual Convention in Snoqualmie, WA, entitled "Opposing Recission of the 2001 Roadless Area Conservation Rule and both Action Alternatives, and Demanding Full Consultation and Analysis of Tribally Requested Alternative Across the Affiliated Tribes of Northwest Indians Region". The Convention took place September 14-17, 2026. ATNI Resolutions are reviewed and vetted through the appropriate ATNI Committee(s) and then approved by ATNI Member Tribes. ATNI represents 57 federally recognized Tribal Nations across Washington, Idaho, Oregon, Montana, Nevada, Northern California and Alaska. We respectfully submit this resolution for your attention and consideration regarding the proposed Roadless Area Conservation rulemaking. As described in the Resolution, ATNI opposes the proposed recission of the 2001 Roadless Area Conservation Rule and both action alternatives, and supports Alternative 1, 'no action', as the only alternative before the Department consistent with treaty rights, the federal trust responsibility, and Alaska National Interest Lands Conservation Act (ANILCA) subsistence protections. Further, ATNI calls on the Department to withdraw the proposed rule and, if it proceeds, to circulate for comment a supplemental Draft Environmental Impact Statement studying the alternatives Tribal Governments asked for, including a traditional homelands conservation rule for the Tongass, a strengthened roadless rule, co-stewardship and co-management with mutual concurrence, Indigenous Knowledge as best available science, and a Tribally initiated mechanism providing expressly for Tribally led fire suppression, fuels reduction, prescribed and cultural burning, and management for resiliency at the direction of the Tribal Government whose homelands are affected. Additionally, ATNI demands a comment period on no fewer than 120 days from publication; a Tribal consultation period of no fewer than 120 days, the Forest Service's own standard for widely applicable national issues (FSH 1509.13) and the commitments in its 2023 Tribal consultation action plan; and full compliance with USDA Departmental Regulation 1350-002. ATNI also demands that consultation be conducted by the Departmental officials who will decide this rulemaking, the Secretary and Deputy Secretary, not local or regional line officers, with sessions accessible across the ATNI region, funding for Tribal participation, written documentation of outcomes, and cooperating agency status for any Tribal Government that asks. ATNI further demands the Department complete and publish a full ANILCA Section 810 evaluation on current information before any Records of Decision, hold additional in-person subsistence hearings in Southeast Alaska communities beyond the one now scheduled, and keep the written record open at least 30 days after the final hearing. ATNI calls on the Department to treat Tribal Governments as sovereigns holding treaty-reserved rights and a trust relationship, not as interested parties, to answer a Tribal Government's request for roadless management in its homelands through government-to-government consultation and agreement, to use Tribal Forest Protection Act authority and Secretarial Order 3403 fully, and to build the mechanism NCAI called for in Resolution #SEA-25-102 by which a Tribal Government may name roadless areas of concern and seek management or co-management, the petition process under 5 U.S.C. 553(e) remaining open but not treated as a substitute for tribal consultation. Finally, ATNI rejects the deferral of treaty rights, sacred sites, cultural resources, water quality, and subsistence protections to future project-level review, and demands that the Department: Analyze those effects in the Final EIS at the scale the decision is being made, and produce a complete consultation log at least 30 days before it issues; Analyze how its concurrent changes to environmental review, objection, travel management, and directives rules affect the project-level review it offers in the Rule's place; Finish formal consultation on treaty-reserved and culturally significant species, and issue no Record of Decision before the biological opinions are disclosed; and Record in the final Tribal Summary Impact Statement all Tribal input through the close of the comment, and state how that input changed the decision. You can find ATNI resolutions at https://www.atnitribes.org/resolutions. Should you have any questions regarding the substance of this resolution, please contact the ATNI Natural Resources Committee Chairs listed below: Andrew Gobin, agobin@tulaliptribes-nsn.gov Paul Ward, warp@critfc.org Respectfully, Katie McDonald Senior Policy Manager, Affiliated Tribes of Northwest Indians

Re: Special Areas; Roadless Area Conservation - proposed rescission, 91 FR 53827 (Aug. 20, 2026) | RIN 0596-AD66 | Docket FS-2025-0001 I oppose rescinding the 2001 Roadless Rule and ask that the Department withdraw the proposed rule, or at minimum adopt an alternative that retains the national baseline and requires site-specific NEPA before any road construction or commercial harvest in inventoried roadless areas. I am a U.S. military veteran and an America the Beautiful Military Lifetime Pass holder. I live in San Francisco, and these areas are where I actually spend my time - the San Gorgonio Wilderness (San Bernardino NF), the Cucamonga Wilderness and the San Gabriel high country around Mount Baldy (Angeles NF), the Mount Pinos country in Los Padres NF, and the eastern Sierra out of Mammoth. The reason those places are still quiet is the 2001 rule. I also drive SR-38 to the Vivian Creek trailhead, which has washed out repeatedly since the 2020 El Dorado Fire - a reminder of what these steep headwater drainages do after fire, and why road density and ground disturbance in them matter. Four specific comments: 1. The stated problem does not require this remedy. USDA keeps the Idaho (subpart C) and Colorado (subpart D) roadless rules and notes that any state, tribe, or entity may petition under 5 U.S.C. 553(e) for tailored management. If place-based roadless rules are workable - and USDA is retaining two - then "one-size-fits-all" is not a justification for repealing the baseline everywhere else. The Department already has the mechanism it says it needs. 2. "Returning decisions to land management plans" is a plan of absence. The notice states the rule "does not require or compel the amendment or revision of any land management plan." For forests whose plans do not independently prohibit road construction and harvest in roadless areas, rescission leaves a gap with no protection until a plan is revised - years, for many units. The final EIS should state, acre by acre, how much of the 58.5 million acres retains equivalent protection on day one and how much does not. The notice asserts effects are "bounded by existing land management plan direction" without demonstrating what that direction is. 3. The economics are close to a wash; the losses are not. USDA's own figures: timber-industry gain of $4.6-10.6M/yr, recreation loss estimated at $6.1M/yr - against a $6.9 billion deferred-maintenance backlog on the existing forest road network. Building new roads you cannot afford to maintain, for revenue the same order as the recreation value displaced, is not a net-benefit case. The road-maintenance liability of new permanent roads is missing from the analysis. 4. Wildfire. The notice concedes greater access "can increase human-caused ignition potential." If road construction is justified as fire-risk treatment, the EIS should quantify treatment acreage actually achievable within operability and budget over ten years, and compare it against the acres each new road puts at higher ignition risk. The 9.8 million WUI acres overlapping roadless areas deserve a spatially explicit alternative, not blanket repeal. Alternative I support: No Action, or a targeted-WUI-treatment alternative permitting fuels reduction and temporary access within a defined distance of at-risk communities while retaining the prohibition on new permanent roads and commercial harvest in the interior of inventoried roadless areas. As a veteran, I value these lands for the quiet, self-reliant recreation they provide, and I ask the Department to keep the protection that makes them what they are. Please withdraw the proposed rule. Brian Mauck - San Francisco, CA

I oppose rescission and urge the agency to select Draft EIS Alternative 1 (No Action), retaining the 2001 Roadless Rule. I am a resident of Bend, Oregon. I've lived her for 5 years and grew up nearby in Eugene, Oregon. About 137,000 acres of the Deschutes National Forest (roughly 9%) are inventoried roadless areas, including Tumalo Mountain, forests along the Cascade Lakes, trails near Tumalo Falls, and lands around Newberry National Volcanic Monument. These are where Bend residents hike, ski, run, fish, and find quiet. The proposal itself concedes that new roads and logging could bring noise, visible infrastructure and closures, tradeoffs with "quiet, remote and self-reliant recreation," and more user conflicts (91 FR 53829-30). A road, once built, is rarely undone, so these losses would be effectively permanent. Visitors and residents spent more than $380 million in Bend in 2023, supporting 3,470 full- and part-time jobs (Dean Runyan Associates, Economic Impact of Travel in Bend, 2023, as cited by the Bend Chamber). The Bend Chamber, representing about 1,750 members and 8,500 Central Oregon businesses, has told the Oregon Legislature that recreation is a critical sector here, anchored by outdoor-product firms like Hydro Flask and OSU-Cascades programs in outdoor product development. Not all of this activity occurs in roadless areas, but the landscape that draws visitors, residents and employers depends on large intact tracts like these. The agency estimates that if every operable acre were harvested (which it calls unlikely), timber revenue to the Treasury and Forest Service would rise $5.2-11.4 million per year nationally, while recreation could lose an estimated $6.1 million per year and additional impacts "could exceed $100 million" (91 FR 53829-30). These measures differ, but the scale matters: the possible national timber gain is small next to the value one community like Bend already draws from its public lands. The agency asked for data on baselines and industry effects (91 FR 53830). I ask that it analyze recreation, tourism and outdoor-industry effects for Central Oregon using local data before any final decision. Recommendations: (a) Select Alternative 1 and retain 36 CFR 294 Subpart B. (b) If the agency pursues fuels reduction, develop narrowly tailored provisions for municipal watersheds and the wildland-urban interface (such as Tumalo Creek) with the City of Bend, Deschutes County and tribes, using the petition process noted at 91 FR 53829 (5 U.S.C. 553(e)), while keeping the rule. (c) At minimum, exclude municipal watersheds and heavily used recreation areas near communities from any rescission. (d) Publish a Central Oregon recreation, tourism and drinking-water impact analysis for public review.

Comment on Proposed Rule: Special Areas; Roadless Area Conservation RIN 0596-AD66 | Docket FS-2025-0001 | 91 FR 53827 I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and ask the Department to withdraw it. My full comment is attached. The Department already knows what the public thinks. Its own preamble reports that the 2025 notice of intent drew more than 220,000 comment letters on behalf of over 625,000 individuals and organizations in twenty-one days, and that "the majority sentiment among Tribal governments consulted is opposition." Independent analysis found opposition above 99 percent of unique submitters. A December 2025 national poll by Susquehanna Polling and Research for The Pew Charitable Trusts found likely voters support the Roadless Rule 76 to 13 percent, with support highest among Republicans at 77 percent; 87 percent said national forest areas should be kept mostly undeveloped and intact, against 7 percent favoring more timber production and roads. The rule being rescinded was adopted on the largest public record in this agency's history: 600-plus hearings and over 1.6 million comments. I ask the final rule to state plainly what public support the Department believes exists for this action, and to identify the evidence for it. Notice-and-comment is not a referendum, and I do not ask the Department to treat it as one. But this record is evidence the APA requires the Department to engage: of the reliance interests it must weigh in reversing a settled policy, of the public values MUSYA and NFMA require it to consider, and of the 2001 factual findings it must confront before abandoning them. The attached comment sets out 49 reasons. The principal ones: Rescission is unnecessary. The preamble itself notes that any State or Tribe may petition for tailored roadless provisions under 5 U.S.C. 553(e) and 7 CFR 1.28. Idaho and Colorado did exactly that, and this proposal preserves both state rules. Local flexibility does not require eliminating the national baseline. The legal questions are settled. The rule was challenged in the Ninth, Tenth, and D.C. Circuits and prevailed in each; the Supreme Court denied certiorari in 2012. No challenge to the 2001 Rule has ever succeeded on final judgment. The suits that did succeed struck down attempts to weaken it, including Organized Village of Kake v. USDA, 795 F.3d 956 (9th Cir. 2015) (en banc), which held the 2003 Tongass exemption arbitrary and capricious precisely because the Department reversed its own 2001 findings without explanation. That is the defect in this proposal, on a national scale. The preamble cites that litigation history as a reason to rescind; it shows the opposite. The economics do not work. The Department projects $5.2-11.4 million per year to the Treasury from timber, against roughly $6.1 million in annual recreation losses and a conceded $6.9 billion deferred maintenance backlog for roads and bridges. It calls the rule economically significant under E.O. 12866 and says impacts "could exceed $100 million," yet certifies no significant impact on small entities under the Regulatory Flexibility Act. Those findings need reconciling. The wildfire rationale is self-contradicting. The preamble concedes "greater public access can increase human-caused ignition potential." Only 24 percent of inventoried roadless acres overlap the wildland-urban interface, so a nationwide rescission is far broader than the stated community-protection purpose requires. The current rule already allows fire and fuels work. The NEPA analysis is segmented. The Department concedes that subsequent plan amendments "could increase the area where timber harvest and road construction would be allowed," then declares those effects beyond scope while soliciting comment on them. It also declines to fully analyze the No Action, Strengthened Roadless Rule, and Traditional Homelands alternatives commenters requested. Tribal consultation is unfinished. Of 64 requests, 34 were scheduled and 29 held. The final Tribal Impact Summary Statement is to issue with the final rule, after comment closes, so neither Tribes nor the public can comment on it. The ANILCA 810 subsistence analysis is likewise outside this period. I ask the Department to withdraw the rule; failing that, to select No Action, fully analyze the requested alternatives and foreseeable plan amendments, publish the Tribal and subsistence analyses for comment before any final rule, reconcile its economic findings, confront its 2001 findings and the reliance built on them, and use the existing petition process for documented local needs. I have hiked the entirety of the Pacific Crest Trail and the Tahoe Rim Trail and explored National Forests in more than twenty states. Much of that ground was inventoried roadless area. These places are drinking water, habitat, and the last unfragmented country we have, and there is no process that makes more of them.

Quoted from FS-2025-0001-223869 “The majority sentiment among Tribal governments consulted is opposition to the proposed rescission of the 2001 Roadless Rule, viewing it as a threat to inherent rights, Tribal sovereignty, cultural survival, and the ecological health of ancestral homelands.” Personally, I believe that is all we need to end the conversation and cancel the proposition to rescind the 2001 Roadless Area Conservation Rule. The corruption in the executive branch is attempting to dismantle our sacred nature, sell her off for parts and bleed her dry. I cannot fathom a more blasphemous legacy. Our legacy needs to be protecting and fostering our natural resources for ALL future generations. The FS-2025-0001-223869 references wildfire risk, but never explains how rescinding the 2001 Roadless Rule would mitigate wildfire risk. There are vague mentions of active management of wildfire risk, but no specific strategies cited. Do they even know how to mitigate wildfire risk? How will rescinding the Roadless Rule benefit wildfire mitigation strategies? Inadequate information is provided by the authors of the FS-2025-0001-223869 document. The existing 2001 Roadless Rule does have avenues for local Forest Service officials to request exemptions. When the forest is being responsibly managed and the exemption is legitimately required, local decision makers can address conservations and resource issues. Rescinding the Roadless Rule and using The Forest and Rangeland Renewable Resources Planning Act of 1974, as amended by the National Forest Management Act of 1976 would not be sufficient for 2027 and future forest stewardship. The Act is outdated and does not have considerations for our current struggle with climate change. In addition, the Act does not have strong guardrails around preventing the mutilation of national forests by private extraction based companies. The simplest conclusion is - do NOT rescind the 2001 Roadless Rule. However, if the Rule is to be rescinded, I demand as an American citizen and an enrolled citizen of the Laguna (federally recognized) tribe that these conditions be met: - Assurance that the NEPA (National Environmental Policy Act) remain intact - A permanent moratorium on logging companies, mining companies, and data center companies operating on National Forest Land - Publicly available database for all Americans to review all petitions submitted to the Administrative Procedure Act (5 U.S.C. 553(e)) and USDA regulations at 7 CFR 1.28 - Local Forest Service officials coordinate a comprehensive environmental review for ALL land management plan revisions - Local Forest Service officials propose ALL land management plan revisions to state ballot initiatives for citizens to directly vote for/against - After ballot initiative passing, local Forest Service officials propose ALL land management plan revisions to federal environmental protections committee - Upon committee review and approval, ALL land management plan revisions submitted to tribals communities with ancestral land connection or current affected interest – rightful stewards of our land – to have final authority to deny the plan revisions

Publishing the draft EIS and cost-benefit analysis alongside the proposed rescission, and preserving the Idaho and Colorado state-specific rules unchanged, gives the public a concrete record to evaluate rather than a bare policy statement. That transparency should be the floor for the rest of the rulemaking, not the ceiling. The rule's central substitution deserves closer scrutiny before finalization. The 2001 Roadless Rule imposed a uniform, nationally enforceable prohibition on road construction, reconstruction, and timber harvest across 58.5 million acres. The proposal replaces that floor with discretionary treatment at the individual forest-plan level: the preamble states a governing land management plan "could still include restrictions" on those activities in former roadless areas, but nothing in the proposed text requires it to. That is not a comparable substitute protection; it is the removal of a floor with no replacement floor specified. If the agency's position is that the planning framework "ensures each land management plan addresses similar conservation objectives," the final rule should say so operationally — with a defined minimum standard reviewable by the public and by courts — rather than describing an outcome that remains entirely optional at the discretion of each individual forest unit's land management plan. The tribal consultation record undercuts the timing of this comment period. The agency itself reports that of 64 requested consultations, only 29 have been held, with consultation "ongoing throughout the rulemaking process," while the "majority sentiment among Tribal governments consulted is opposition" to the rescission. Closing public comment on September 21, 2026 while more than half the requested consultations remain incomplete risks finalizing a rule before the government-to-government input Executive Order 13175 is meant to capture has actually been received. The agency should either extend consultation ahead of any final rule or explain concretely how consultations completed after the comment deadline will still shape the decision. The economic analysis, while more detailed than many NPRMs provide, does not reconcile its own numbers, and the gap is not a rounding matter. Every quantified category in the preamble points downward from the top-line figure: timber is estimated at $5.2 to $11.4 million per year to the Treasury and Forest Service plus $4.6 to $10.6 million to industry; recreation losses are estimated at roughly $6.1 million annually; commercial fishing is expected to see no significant change; and leasable minerals are expected to produce "no net change, relative to baseline conditions." Taken at their stated maximums, the disclosed categories total roughly $22 million in annual effect. The preamble nonetheless states that additional impacts "could exceed $100 million," with no table or methodology bridging the resulting gap of nearly $80 million. The Unfunded Mandates analysis later in the same document states the rule would not compel expenditure of $100 million or more in any one year — a defensible distinction, since that provision measures compelled expenditures rather than aggregate economic effects, but one the document never explains. The final rule should publish a single reconciled accounting identifying which unquantified categories carry the difference between roughly $22 million and $100 million. A related gap concerns the petition process the preamble describes for states, Tribes, or other entities seeking tailored roadless provisions under 5 U.S.C. 553(e) and 7 CFR 1.28. The proposal treats this petition avenue as an adequate safety valve for parties seeking protections narrower or broader than whatever a given forest plan ultimately adopts, but a discretionary petition for future rulemaking is not equivalent to the substantive rights available under the current, nationally binding rule. The final rule should clarify what standard the Department will apply in deciding whether to grant such a petition; without one, the petition process is itself another layer of unbounded discretion layered on top of the plan-level discretion described above. These comments identify structural gaps in the proposal, not a rejection of the underlying policy judgment that management flexibility may be warranted. The rulemaking's own record — the incomplete consultation, the unreconciled cost figures, and the undefined petition standard — is what should be resolved before finalization, regardless of the ultimate outcome on rescission.

The Roadless Rule was intended to protect wilderness that had never had human contact. And although some of the areas the rule covers have had human contact, we should not continue to ‘touch it’, and instead use these areas for further research on how wilderness can protect us! Roadless areas protect wildlife, clean water, climate resilience, and ecological connectivity, and provide a baseline for scientific research and data collection. Once roads are built, habitat fragmentation and ecosystem impacts can persist for decades. At a time when biodiversity loss and habitat degradation continue to threaten wildlife across the United States, the Forest Service should be strengthening protections for roadless areas rather than eliminating them. The intent of this proposed action is to reduce regulatory burden and return decision-making for the management of inventoried roadless areas to the land management planning process at the individual national forest level, informed by Tribes, State, and local communities (Executive Order 14192, Unleashing Prosperity Through Deregulation). While I am a strong proponent of subsidiarity, the pressures seen by state and local governments will compel short-term decisions and sacrifice the long-term protections intended by the original rule. The USDA will tell you that rescission of the national-level prohibitions provides responsible officials with flexibility to better guide management of National Forest System lands and respond to changing local resource conditions. The Forest and Rangeland Renewable Resources Planning Act of 1974, as amended by the National Forest Management Act of 1976, and the associated land management planning processes and plans are the appropriate and effective mechanisms to guide sustainable, integrated management of the resources within the plan areas in the context of the broader landscape, giving due consideration to the relative values of the various resources in particular areas. However, after rescindment, any State, Tribe, or other interested entity seeking to establish roadless management provisions tailored to specific geographic or resource conditions must submit a petition for rulemaking under the Administrative Procedure Act (5 U.S.C. 553(e)) and USDA regulations at 7 CFR 1.28, which will be a costly and onerous process, which likely will not result in any change to the inventoried roadless area provisions. The USDA will also tell you that rescinding the Roadless Rule could help address wildfire risk, but recent peer-reviewed research suggests otherwise. A 2026 study found that wildfires are approximately four times more likely to ignite near roads than in roadless areas (R.T., et al. (2026). Human access and wildfire ignition patterns in roaded and roadless forests. Fire Ecology, 22. https://link.springer.com/article/10.1186/s42408-026-00450-2). Roads increase human access and human-caused ignition sources, including unattended campfires, discarded cigarettes, and vehicle-related sparks. Opening intact backcountry forests to additional road construction is not a sound wildfire prevention strategy. The Environmental Impact statement estimates rescindment will result in permanent road construction in 45% of current Roadless Rule Land (RRL) (18.2M acres), and temporary road construction in 28% additional RRL (11.3M acres); providing more human access and removing the forest that would mitigate the climate change that the Forest Service blames for increased wildfire risk. The construction of roads always alters drainage and often contributes to erosion and lowered water quality. Through the Environmental Impact Statement, the USDA will claim that rescindment will result in $5.2 to $11.4 million per year in revenue to the Treasury and Forest Service and $4.6 to $10.6 million per year in revenue to the timber industry, but it also predicts losses in economic benefit to recreationists associated with the operable areas could be an estimated $6.1 million annually. Temporary impacts to recreation and related industry opportunities, include noise, visible infrastructure, and temporary closures. In the longer term, developed and road-based recreation could expand through development of some new permanent roads, though this expansion is uncertain and anticipated to be limited due to land management plans, budget, and resources. This expansion could increase road-based recreation and accessibility improvements but would result in tradeoffs with opportunities for quiet, remote and self-reliant recreation and may increase user conflicts and result in lost economic benefits. Thank you for your consideration.

Public Comment Opposing the Proposed Rescission of the 2001 Roadless Area Conservation Rule Docket: FS-2025-0001 RIN: 0596-AD66 Submitted via regulations.gov Comment deadline: September 21, 2026 To the Director, Ecosystem Management Coordination: I own and run a tree service company in Okanogan County, Washington. Vegetation management, hazard trees, and fuels work are how I make my living, in a valley that has burned several times in the last fifteen years. I am writing to oppose the proposed rescission of 36 CFR part 294, Subpart B. I am not against active management on these lands. I am against removing a national standard and replacing it with the promise that project level review will catch whatever the standard used to catch. The proposal calls that a reduction in regulatory burden. What it actually does is move the scrutiny from one settled decision onto a project by project process that is already short on staff, already slow, and already the part of the work that gets contested. The proposal admits its own analysis is incomplete. Under Summary of Potential Impacts, the Department says that later land management plan amendments and revisions could increase the area where timber harvest and road construction would be allowed, and could produce impacts beyond what is summarized in the analysis. It then sets those changes aside as outside the scope. That is the heart of my objection. Rescission does not approve any project on its own. It removes the floor, and the proposal states plainly that the new floor is whatever each forest plan says at the time, and that plans can be amended. An analysis that leaves out the foreseeable results of the action is not a good enough basis for taking it. The economics in the proposal do not support the stated purpose. The Department estimates $5.2 to $11.4 million a year in revenue to the Treasury and Forest Service, and $4.6 to $10.6 million a year to the timber industry. That is about $22 million a year at the top end. The same document cites a $6.9 billion deferred maintenance backlog on roads and bridges, and about $6.1 million a year in lost economic benefit to recreationists. Even using the most favorable numbers in the proposal, the yearly upside comes to roughly three tenths of one percent of a road maintenance bill the agency already cannot pay. Adding road miles on top of that backlog is not deregulation. It is a cost pushed down the road. Anybody who runs equipment for a living knows what an unmaintained road turns into, and what it does to the drainage below it. The wildfire argument does not match what I see in the field. The proposal treats the 2001 rule as the thing limiting mechanical thinning and fire control options. In this region the real limits are crew availability, contracting capacity, appropriated funding, burn windows, and the fact that there is almost no market for small diameter material. Making 4.8 million acres eligible, which is 16 percent of the forested area in the potentially affected roadless areas, does not create crews or contracts or mills. The proposal concedes as much when it says harvest across all of it is unlikely because of budgets, operability limits, and market conditions. The proposal also acknowledges that more public access can raise the chance of human caused ignitions. In a county where roadside starts are routine, that is not a small thing to trade away. The small business certification does not line up with the rest of the document. The Department certifies that the rule will not have a significant economic impact on a substantial number of small entities. Elsewhere the same document says additional annual impacts could exceed $100 million and that recreation and tourism could see trade offs. Recreation dependent small businesses in the Methow Valley and across the eastern Cascades are exactly the kind of small entities that certification is supposed to account for. I think it should be withdrawn and a full analysis prepared. What I am asking for is that the Department choose the No Action alternative and keep 36 CFR part 294, Subpart B as it stands. If certain roadless areas genuinely need more flexibility for community protection in the wildland urban interface, the existing petition process under 5 U.S.C. 553(e) and 7 CFR 1.28 is still available. That is the process that produced the Idaho and Colorado rules. Targeted exceptions for specific places are defensible. Rescinding the whole thing nationwide to get them is not. I will add that the proposal itself reports that most of the Tribal governments consulted oppose the rescission, and that the earlier comment period drew more than 220,000 letters on behalf of over 625,000 individuals. That record should count for something. Respectfully, Chris Moore - Owner, HingePoint Tree Service, Inc. Winthrop, Washington

Comment on Special Areas; Roadless Area Conservation RIN 0596-AD66 | Docket No. FS-2025-0001 | 91 FR 53827 I oppose Alternative 2 and Alternative 3 and ask the Department to develop a modified alternative in the Final EIS. A fuller comment with citations is attached. This is not an argument for "no action." The preamble identifies real problems, including inconsistent use of the existing exceptions. Those support amending the rule, not rescinding it. 1. The wildfire rationale is not supported by the ignition record. Aplet et al. (2026, Fire Ecology 22:8) matched all National Forest System ignitions from 1992 to 2024 to the agency's road layer. Ignition density was 7.99 fires per 1,000 hectares within 50 meters of a road, against 1.97 in inventoried roadless areas and 1.75 in wilderness, a gradient holding in all eight contiguous-U.S. regions. The largest 2% of fires, which drive nearly all area burned, showed no meaningful size difference by origin. The DEIS reports the same pattern, and that Forest Service fire scientists caution additional roads could increase human-caused ignitions. If roads do not shrink the fires that threaten communities but reliably increase ignitions, road construction is not a net reduction in risk. The Final EIS should quantify the net change in annual ignitions under each alternative. 2. The treatment geography does not match the stated purpose. The rule states that 24% of affected roadless areas overlap the wildland-urban interface. Roughly 76% do not. Rescission would expand management opportunity on about 4.8 million acres, a gain the rule itself calls modest. Cohen (2000) and Calkin et al. (2014) show structure ignition is governed by the home ignition zone, not stands kilometers upslope. An alternative scoped to the interface would capture nearly all that benefit at a fraction of the ecological cost. 3. The forest plan backstop assumption is not supported. The rule identifies 18.2 million acres where plans already permit permanent roads and only the 2001 Rule prohibits them, measuring how much protection rests on the rule, not on plans. Where a plan is silent, rescission removes the only constraint, and plans are amendable by the same officials proposing the projects. The rule concedes amendments could expand effects beyond those analyzed, then treats that foreseeable consequence as outside scope. Under NEPA it is not. 4. The economics do not close. Under the Department's own upper bound, harvesting all newly operable acreage annually yields $4.6 to $10.6 million per year to industry, against roughly $6.1 million in lost recreation benefit, a DEIS finding that timber revenue would not cover building and maintaining new project roads, and a $6.9 billion road maintenance backlog. The Final EIS should present net fiscal effect inclusive of maintenance liability. 5. On access, the diagnosis is misplaced. The 2001 Rule closes nothing and does not prohibit fire suppression, prescribed fire, non-commercial thinning requiring no new road, or motorized use of existing routes. Access lost over two decades has gone to travel management and deferred maintenance on the existing road system. 6. Requested alternative. Retain 36 CFR 294 Subpart B and amend it: (a) authorize treatment and roads within the wildland-urban interface or 1.5 miles of an at-risk community, temporary roads only absent Regional Forester approval, restored within three years; (b) delegate 294.13(b)(1) determinations to forest supervisors with national guidance and decision timelines; (c) require road-density neutrality, offsetting each new permanent mile with one decommissioned on the same unit; (d) use the Idaho (2008) and Colorado (2012) rules as the model for place-based variation through petitions under 5 U.S.C. 553(e), which already show flexibility does not require repeal; (e) carry forward co-stewardship concepts raised in Tribal consultation; (f) require annual reporting of miles built, miles decommissioned, and acres treated. 7. Procedural requests. Extend the comment period to 90 days; thirty is well below the 60-90 customary for a 333-page Draft EIS. Complete ESA Section 7 consultation before a final rule, given the preliminary determination of likely adverse effect to 327 listed species and 71 critical habitats. Complete ANILCA Section 810 findings before the decision. Address reliance interests built over 25 years by outfitters, state agencies, and community wildfire planning. Virginia's roughly 394,000 roadless acres on the George Washington and Jefferson National Forests are not fire-deficit western systems. They matter for interior forest birds, wild brook trout, and the world's richest plethodontid salamander fauna. The Final EIS should analyze Eastern Region roadless areas separately. Thank you for considering these comments. Ryan Pranschke Wildlife & Landscape Photographer and Conservationist Aldie, Virginia

I am writing as a member of the public to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66, Docket FS-2025-0001). I grew up hiking in the White Mountain National Forest, including Cannon Mountain which I see is affected, and the backcountry I walked as a kid is still backcountry because of this rule. I am not against local decisionmaking — but the Department already has it. Idaho and Colorado operate under state-specific roadless rules this proposal leaves untouched, and the preamble confirms that any State, Tribe, or interested entity may petition for tailored provisions under 5 U.S.C. 553(e). Flexibility does not require repeal. The Department’s own numbers do not justify the trade. It estimates that harvesting every operable acre — unlikely by its own account — would return $5.2 to $11.4 million a year, against roughly $6.1 million in annual lost economic benefit to recreationists, and it concedes the resulting opportunities would be modest and localized. It cites a $6.9 billion deferred maintenance backlog on roads and bridges that new construction would only deepen. It admits greater public access can increase human-caused ignition potential, and that only 24 percent of affected roadless acres overlap the wildland-urban interface. It reports that the majority of Tribal governments consulted oppose the rescission. That is a great deal to give up for very little. Please retain the rule, so the places I hiked as a child are still there for the kids hiking now.

RIN 0596-AD66 / Docket FS-2025-0001 Comment on the Proposed Rescission of the 2001 Roadless Area Conservation Rule and the Draft EIS I oppose full rescission. I support the No Action alternative. If USDA needs more flexibility, scope it to the wildland-urban interface and use the petition process that already exists. My objections come from the agency's own preamble. To be clear up front: I am not against active management. I live in the West, in fire country, and wildfire is not theoretical where I am. Thin the WUI, cut fuel breaks, salvage dead stands, run prescribed fire. I will back all of it. Rescission is not that tool, and the record shows why. 1. ACCESS IS NOT THE BINDING CONSTRAINT. CAPACITY IS. The preamble states 11.3 million roadless acres (28.3%) already sit within a half mile of an existing road. The Chief states only 5% of high-hazard roadless acres have been treated since 2014. If access were the limiting factor, those 11.3 million already-reachable acres would be treated. They are not. The constraint is crews, contracts and appropriations. Request: the FEIS should disclose treatment rates inside versus outside IRAs, and inside versus outside that half-mile band. If the rates are comparable, the purpose and need fails on the agency's own data. 2. THE ECONOMICS DO NOT CLEAR THE TAXPAYER BAR. Preamble figures: $5.2M-$11.4M per year to the Treasury and Forest Service, $4.6M-$10.6M per year to the timber industry, against an acknowledged $6.9 billion deferred maintenance backlog on roads and bridges and roughly $6.1M per year in lost recreation benefit. Best case, the timber upside is a rounding error against the backlog and is largely cancelled by the recreation loss. At the low end of the agency's own range it is net negative. Request: model full lifecycle cost per new road mile (construction, maintenance, culverts, decommissioning) and disclose the net fiscal position. Adding assets we cannot maintain is how the backlog reached $6.9 billion. 3. ROADS CARRY IGNITIONS. THAT IS THE AGENCY'S OWN SCIENCE. Roughly nine in ten wildfires are human-caused. Forest Service researchers mapped 26 years of ignitions along about 850 miles of road in the Angeles, San Bernardino, Los Padres and Cleveland National Forests. The preamble itself concedes that greater access "can increase human-caused ignition potential." Request: quantify it. Model expected additional ignitions per new road mile against expected acres treated and show the net change in community risk. Right now the fire rationale is asserted, not calculated. 4. THIS REDUCES LOCAL CONTROL. IT DOES NOT INCREASE IT. Idaho and Colorado already built their own roadless rules by petition under 5 U.S.C. 553(e), and this proposal leaves both intact. That is proof the current framework is not one-size-fits-all. States that wanted tailoring got it. Full rescission does not hand decisions to local officials. It removes the floor and pushes every acre into plan revisions and project-level NEPA: more federal process, more litigation, more delay. That runs against the stated deregulatory purpose of E.O. 14192. 5. RELIANCE INTERESTS, SINCE THE PREAMBLE ASKS FOR THEM. Twenty-five years of private investment sits on this rule. Outfitters, guides, ranchers whose operations depend on intact headwaters, and the lodging, fuel, food and retail businesses in gateway towns whose product is the country next door. I am on the customer side of that economy, and my money goes to those towns because of what surrounds them. In 2024 outdoor recreation was $1.3 trillion in output, 2.4% of GDP and 5.2 million jobs, and hunting and shooting was the fastest-growing category in it at 16.5%. A projected $6.1M annual recreation loss does not credibly describe that exposure. It is a placeholder. 6. TAILORING. The community-protection rationale rests on WUI overlap: 9.8 million acres, 24%. Rescinding 100% of the rule to reach 24% of the acres is not narrow tailoring. A WUI-scoped alternative delivers the fire benefit without the rest, and I would support it. 7. PROCESS. The 2001 rule came out of 600 public meetings and 1.6 million comments. This round is 30 days with no public meetings, on a proposal the preamble concedes could exceed $100 million in annual effects. That gap will be the first thing a court looks at. One last thing. I camp on Forest Service ground, dispersed sites off forest roads across the Eastern Sierra, the Great Basin and the Northern Rockies. I photograph the night sky out there because dark sky has a hard boundary: it exists where roads and lights do not, and there is less of it every year. That country is an asset on the national balance sheet, and it took 25 years to stop borrowing against it. Roosevelt understood you do not liquidate the principal to make a quarter. Keep the rule. Fund the treatments. Use petitions where states want something different. A supporting statement with citations and a fiscal table is attached.

I oppose this rescission and support the No Action alternative. I am a New Hampshire resident. The agency must respond to each of the following in the record: 1. The agency's own analysis defeats its stated purpose. USDA estimates rescission would expand active management on roughly 4.8 million acres — 16 percent of forested acreage in affected inventoried roadless areas — and concedes harvest there is unlikely given budgets, operability, and market conditions. An action justified by management necessity that the agency itself expects to be modest, localized, and largely unexercised is not justified by management necessity. Explain why a nationwide rescission is the proportionate remedy for a benefit the agency describes as marginal. 2. The wildfire and insect rationale does not apply to the Northeast, and the rule is nationwide. The White Mountain National Forest does not carry a stand-replacing fire regime. Rescission delivers essentially none of the claimed benefit in New Hampshire while imposing the full road footprint. If the need is regionally specific, justify why the remedy is not. 3. Reconcile the road maintenance figures. The proposal cites a $6.9 billion deferred maintenance backlog for roads and bridges. Commenters have documented $10.8 billion across 370,000 miles, a majority attributable to deteriorated roads causing sedimentation and fish passage barriers. Adding road mileage to a system the agency cannot maintain is not management. State the correct figure and explain how new construction is funded against it. 4. Reconcile the New Hampshire acreage. The record variously describes 235,000 and more than 265,000 acres of inventoried roadless area in the White Mountain National Forest. Publish the controlling number and its basis. 5. The agency has already demonstrated what it does with this discretion. Roadless acreage identified in the 2005 White Mountain Forest Plan fell outside the 2001 rule, and the Forest Service asserted it owed those lands no comparable protection, then proposed logging in them — including South Carr Mountain, Mill Brook, and Kanc 7. This is documented agency conduct, not speculation. Address it directly. 6. The local-decisionmaking premise fails without local staff. The entire rationale rests on forest supervisors exercising informed place-based judgment. Forest Service staffing has been reduced. Provide the staffing levels assumed by this proposal and the analysis supporting them. 7. The petition pathway converts a national trust into a patchwork. The proposal invites petitions under 5 U.S.C. 553(e), with Idaho and Colorado as precedent. National Forest System lands are held for all citizens, not for whichever party petitions hardest. Explain how the agency will prevent fragmentation of a national standard into state-by-state exemption. 8. Reliance interests and Tribal consultation. The proposal solicits comment on reliance interests; twenty-five years of recreation economies, conservation easements, and land use decisions built on this rule are such interests, and the agency must weigh them, not merely note them. USDA also determined that E.O. 13175 consultation was warranted here and then documented majority Tribal opposition. Finalizing over that record demands explanation. In New Hampshire the trade is a $3.9 billion outdoor recreation economy against a $1.4 billion forest products industry, and the agency's own estimate of $6.1 million in annual lost recreation benefit nationally. Retain the rule. Adam Davidson Derry, New Hampshire

RIN 0596-AD66 | Docket FS-2025-0001 Born in Sheridan, Wyoming to a ranching family, raised in Colorado, property owner in Skagit County, Washington. Hunter, veteran, member of Backcountry Hunters & Anglers, Ducks Unlimited, and Washington Waterfowl Association. I oppose the rescission. I am not against roads or active management. My objection is that the preamble's own findings do not support the action. 1. THE PREAMBLE CONCEDES WHAT DEFEATS THE PURPOSE. At 91 FR 53829 the Department states opportunities would be "modest and localized" and that gains are "limited by road costs, maintenance funding gaps, and the $6.9 billion deferred maintenance backlog." I agree. If the constraint is budgetary, removing the regulation cannot produce the benefit. Request: show with funding and workforce analysis how rescission yields one additional treated acre. 2. THE AUTHORITY ALREADY EXISTS. 36 CFR 294.12(b) permits roads to protect public health and safety including imminent fire threat; 294.13 permits fuels cutting. That exceptions proved "limited and inconsistent due to associated reviews and approvals" describes a guidance problem, fixable by guidance. Request: analyze an alternative clarifying those sections while retaining Subpart B. 3. THE FIRE RATIONALE DOES NOT MATCH THE GEOGRAPHY. The Department reports WUI overlaps 9.8 million acres, 24 percent of affected roadless areas. Three-quarters is not community protection. Request: analyze in detail a WUI-bounded alternative removing the prohibitions only near at-risk communities and critical infrastructure. 4. IGNITION RISK IS CONCEDED BUT NOT QUANTIFIED. The Department acknowledges access "can increase human-caused ignition potential." Published analysis finds ignition density lowest in wilderness and roadless areas, highest near roads. An action justified as fire risk reduction that may increase ignitions requires a net-risk estimate. Request: quantify change in ignition density, acres burned, and suppression cost. 5. THE ECONOMICS DO NOT FAVOR THE ACTION. The Department estimates $5.2-11.4 million per year to the Treasury and Forest Service and $4.6-10.6 million to industry under a full-harvest scenario it concedes is unlikely, against roughly $6.1 million in annual recreation losses. The upper bound of an improbable case roughly equals the loss it creates, before maintenance liability. Request: count lifecycle cost of new permanent roads, capital plus perpetual maintenance, as a quantified cost. 6. RELIANCE INTERESTS. The Department invites comment on these but analyzes none. I bought property in Skagit County against a management baseline settled for 25 years. So did outfitters who built businesses on backcountry opportunity, and WDFW in setting seasons premised on existing security habitat. An agency reversing longstanding policy must assess serious reliance interests and explain why it discounts them. A solicitation is not an assessment. 7. ANALYZE A STATE-SPECIFIC ALTERNATIVE NOW. The Department preserves the Idaho and Colorado rules and invites petitions under 5 U.S.C. 553(e). I was raised in Colorado and know that country. It is a workable model, but it was built on top of an existing protection, not in the vacuum left by removing one. Idaho and Colorado negotiated from a protected baseline. Washington would petition only after protections are gone, bearing the burden of restoration rather than change. Request: analyze a state-specific alternative in detail, or explain why the tailored approach preserved in two states is unsuitable everywhere else. 8. RESOURCE EFFECTS NEED REAL SCALE. Washington's roadless areas, about 2.015 million acres or 22 percent of state national forest land, include headwaters in the upper Skagit and on the Olympic Peninsula overlying critical habitat for listed salmonids. Roads are the dominant sediment source and driver of mass wasting in this terrain. Request: quantify sediment delivery and culvert failure risk at the fifth-field watershed scale and confirm ESA Section 7 consultation status. Open road density is also among the best predictors of elk distribution and bull survival; with permanent road additions anticipated across 18.2 million acres, the effect on hunting opportunity is direct and foreseeable. Request: analyze against published road-density thresholds with state agency consultation on record. The 2001 Rule is fiscally conservative policy. It needs no appropriation and creates no recurring liability. The Department has told the public the benefits are modest, localized, limited by a $6.9 billion backlog, roughly offset by recreation losses, and possibly accompanied by more ignitions. That record does not support removing protection from 44.7 million acres. I request the No Action alternative, or a supplemental draft EIS analyzing the alternatives above with the missing reliance-interest and lifecycle-cost analyses. Burlington, Washington

I am an outdoor recreationist who frequently uses the Arapaho and Roosevelt National Forests. Every source I cite is federally funded and most is USDA Forest Service research. The agency must reconcile this proposal with the science it produces, and has not. I recognize the rule removes only Subpart B and that Subparts C and D remain in effect. That is itself strong evidence against the Purpose and Need. Colorado and Idaho show that place based tailoring is already available inside the roadless framework, through the 5 U.S.C. 553(e) petition process the preamble itself points to. The DEIS never explains why that mechanism is inadequate, nor why the alternative to a national rule is no rule rather than more state rules. That alternative must be analyzed. The Forest Service is publishing the California Southern Zone Human Caused Fire Ignition Analysis, mapping 26 years of ignitions across four national forests and 850 miles of roads. It finds roughly two thirds of human caused fires start along roadsides, and the agency is using it to prioritize treatment along existing roads. It cannot rely on that operationally while ignoring it when proposing new roads. Downing et al. (2022), with Rocky Mountain Research Station coauthors, found most cross boundary fires start on private land, and that on national forests road density was the strongest predictor of ignitions. My father spent 20 years with the Forest Service. Field staff have long understood that roads into backcountry terrain do not stop fires, they introduce what starts them. The DEIS anticipates permanent roads across 18.2 million acres and temporary roads across 11.3 million acres and converts neither into expected ignitions, though it maintains the FPA-FOD and InFORM databases and its own roads and IRA layers. The Final EIS must model ignition density under both alternatives. The 9.8 million acre WUI overlap figure is undifferentiated by distance from structures. Cohen (2000), written at the agency's Missoula Fire Sciences Laboratory, established that structural survival depends on conditions within 30 to 60 meters of the home, a finding USGS work (Syphard 2014) later confirmed empirically. Calkin et al. (2023), led by Forest Service researchers, concluded that wildland urban fire disasters are not a wildfire problem and that agencies managing wildland fuels have limited impact on community destruction. The Final EIS must report what fraction of the 9.8 million acres lies within 30 to 60 meters of habitable structures, and what fraction is untreatable solely because of Subpart B. Barnett et al. (2016) found only a 6.8 percent encounter rate between federal treatments and later wildfire. PNW-GTR-509, the agency's own roads synthesis produced alongside the 2001 rule, documents sediment production, hydrologic alteration, invasive spread, and passive use value loss. RMRS-GTR-42-vol.6 documents the grass fire cycle, PNW-GTR-846 landscape scale fragmentation, and RMRS-GTR-114 post fire sedimentation costs to a Front Range municipal supply. The DEIS engages none of these and never says which of its own findings the agency now believes wrong. The DEIS bounds its impacts with existing plan direction, concedes that later amendments could expand harvest and roads beyond those impacts, then declares amendments out of scope while requesting comment on them. Amendments enabled by rescission are reasonably foreseeable and must be analyzed, not deferred. The economics have the same defect: the preamble concedes a $6.9 billion road maintenance backlog without disclosing the added liability from 18.2 million newly available acres. The preamble invites comment on these. I have organized my recreation around the roadless system for years because roadlessness delivers a low density, self reliant experience roaded lands cannot. The $6.1 million annual recreation loss figure obscures a class of experience no amendment restores once a road is built. The DEIS fails to demonstrate a net wildfire benefit and fails to analyze the amendments and reliance interests its own preamble identifies. Every deficiency above is documented in research the government paid for and the Forest Service largely produced. The Forest Service must adopt the No Action Alternative and preserve these roadless areas intact. Sources, all federally funded: https://www.fs.usda.gov/about-agency/features/fire-never-starts https://doi.org/10.1038/s41598-022-06002-3 https://doi.org/10.1073/pnas.2315797120 https://doi.org/10.1071/WF13158 https://doi.org/10.3390/f7100237 https://www.fs.usda.gov/pnw/pubs/pnw_gtr509.pdf https://www.fs.usda.gov/rm/pubs/rmrs_gtr042_6.pdf https://research.fs.usda.gov/treesearch/38282