Read the comments.

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 I request that the certification be withdrawn and an Initial Regulatory Flexibility Analysis prepared under 5 U.S.C. 603. 2.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.