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Docket FS-2025-0001 / RIN 0596-AD66 / 91 Fed. Reg. 53827 (Aug. 20, 2026) Special Areas; Roadless Area Conservation -- Proposed Rescission I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Department to select the No Action alternative. I am a physician with 21 years of clinical experience, a father of two daughters, and a lifelong outdoorsman who has hunted, fished, hiked, camped, climbed, and biked across unroaded public land my entire life. I submit a detailed comment as an attachment and summarize its principal objections here. 1. The record does not show the 2001 Rule blocked needed management. The preamble asserts the Rule limited vegetation management but identifies no project denied or abandoned because of subpart B, no count of section 294.13(b) exception requests, and no data on the burden of that exception process. Under State Farm, an agency must examine the relevant data and articulate a rational connection between the facts found and the choice made. That connection is absent. 2. The Department's own figures contradict its justification. The preamble calls the effects "modest and localized" (53829) while designating the rule economically significant with impacts that "could exceed $100 million" (53830). It finds no substantial direct effects on States but substantial direct effects on Tribes for the same action (53831). It justifies rescission by wildfire risk while conceding expanded access "can increase human-caused ignition potential" (53829), and never nets the two. It reports that only 24 percent of inventoried roadless acreage lies in the wildland-urban interface -- meaning 76 percent is not, and the remedy is grossly overbroad relative to the stated need. 3. The economics do not support the action. Claimed timber revenue of $5.2 to $11.4 million per year is largely offset by an acknowledged $6.1 million per year in lost recreation benefit, and is dwarfed by the Department's own $6.9 billion deferred road maintenance backlog. Building new roads the agency cannot maintain converts a speculative one-time gain into a permanent unfunded liability and a chronic source of sediment in municipal watersheds. 4. The Regulatory Flexibility Act certification is unsupported. The Department certifies no significant impact on small entities two pages after estimating millions in annual losses falling on outfitters, guides, and recreation businesses that are small entities under 5 U.S.C. 601(6). It should withdraw the certification and prepare an Initial Regulatory Flexibility Analysis. 5. Reliance interests are solicited but never analyzed. Twenty-five years of reliance by water providers, state wildlife agencies, Tribes, and recreation-dependent businesses is identifiable and substantial. Regents requires the agency to assess and weigh it, not merely ask about it. 6. The process is incomplete. Of 64 requested Tribal consultations, only 29 had been held when this proposal published, and the Department itself found substantial direct effects on Tribes warranting consultation under E.O. 13175. ANILCA Section 810 subsistence hearings are scheduled after the comment period closes, so the public cannot comment on the subsistence findings. As a physician I would add that the preamble treats two public health questions as afterthoughts: source-water protection for communities that draw municipal supply from National Forest watersheds, and wildfire smoke exposure, which is fire's dominant health burden and is nowhere analyzed. Requests: withdraw the proposed rule and retain 36 CFR part 294, subpart B. In the alternative, extend the comment period to at least 120 days; complete all 64 Tribal consultations and the ANILCA Section 810 evaluation and reopen comment; withdraw the RFA certification; and publish the exception-request record, a forest-by-forest inventory of which plans would maintain roadless protections absent subpart B, and a reliance-interest analysis. Full comment attached. Stacy Johnson Salt Lake City, Utah August 30, 2026

I oppose the proposed rescission. My objections concern specific deficiencies in the proposed rule, the Draft EIS, and the cost-benefit analysis. I request a response to each in the Final EIS. 1. The Regulatory Flexibility Act certification is inconsistent with the Department's own analysis. USDA certifies that the rule will not have a significant economic impact on a substantial number of small entities (91 FR 53831). In the same document it estimates $6.1 million in annual lost economic benefit to recreationists, states that recreation and tourism could experience trade-offs, and acknowledges total additional impacts could exceed $100 million (91 FR 53830). Outfitters, guides, lodges, and rural recreation businesses are overwhelmingly small entities under 5 U.S.C. 601(6). A certification under 5 U.S.C. 605(b) cannot rest on the absence of compliance obligations when the agency has separately quantified losses concentrated in a small-entity sector. Loss of the resource a business depends on is an economic impact. I request that the certification be withdrawn and an Initial Regulatory Flexibility Analysis prepared under 5 U.S.C. 603. 2. The federalism determination contradicts the preemption statement in the same document. USDA finds no federalism implications under E.O. 13132 (91 FR 53831), then states under Civil Justice Reform that upon publication all State and local laws and regulations that conflict with the proposed rule or that impede its full implementation would be preempted (91 FR 53832). A rule that preempts conflicting state and local law by its own terms has substantial direct effects on the States. This inconsistency should be resolved on the record before a final rule issues. 3. The wildfire rationale is not supported by the Department's own figures. Only 4.8 million acres, 16 percent of forested inventoried roadless area, are estimated to be operable for timber harvest, and USDA concedes a $6.9 billion deferred road maintenance backlog constrains activity (91 FR 53829). The existing rule already permits cutting generally small diameter timber to maintain or restore ecosystem composition and structure, expressly including reducing the risk of uncharacteristic wildfire effects, under 36 CFR 294.13(b)(1). Small-diameter material is precisely what hazardous-fuels reduction targets, and prescribed fire is not restricted at all. If the binding constraints are funding, workforce, and operability, rescission does not address the stated need. I request that the Final EIS disclose how many proposed hazardous-fuels projects in inventoried roadless areas since 2001 were denied, withdrawn, or materially modified because of 36 CFR 294.13, as distinct from budget or capacity limits. The preamble also concedes that greater access can increase human-caused ignition potential (91 FR 53829) without quantifying it or netting it against the claimed benefit. 4. Reliance interests are not analyzed. The preamble invites comment on reliance interests (91 FR 53830), and an agency reversing a longstanding policy must address the serious reliance the prior policy engendered. FCC v. Fox Television Stations, Inc., 556 U.S. 502, 515 (2009); DHS v. Regents of the Univ. of Cal., 591 U.S. 1, 30 (2020). The Final EIS must address municipal and rural water systems whose source-water planning assumes undeveloped headwaters; recreation businesses that invested in unroaded settings; state wildlife agencies whose habitat and migration-corridor investments assumed a roadless baseline; Tribal governments; and Endangered Species Act consultations that treated roadless conditions as part of the environmental baseline. Stating that near-term effects are bounded by existing plan direction is a prediction about timing, not an analysis of reliance. 5. The range of alternatives appears inadequate under NEPA. Tribes requested a strengthened roadless alternative and a Traditional Homelands Conservation Rule during scoping (91 FR 53832). If these were not analyzed in detail, reasonable alternatives raised in scoping have been excluded. Intermediate options that would serve the stated purpose with less environmental effect also warrant detailed analysis, including broadening the existing 294.13(b) exception near the wildland-urban interface, or a state-petition pathway modeled on the Idaho and Colorado subparts. 6. Thirty days is not a meaningful opportunity to comment on a multi-volume Draft EIS, cost-benefit analysis, and Tribal impact statement covering 44.7 million acres. I request an extension to at least 90 days. I urge selection of the No Action alternative.