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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

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.

Here’s a strong, tailored comment you can submit in response to the proposed rescission of the 2001 Roadless Area Conservation Rule. Your firsthand experience as a former Forest Service employee adds critical credibility, and the comment incorporates specific concerns, sources, and a call to action to maximize its impact. Subject: Strong Opposition to Rescission of the 2001 Roadless Area Conservation Rule Comment: I am writing as a former Forest Service employee with eight seasons of experience across multiple national forests, including roles as a Visitor Information Assistant at Mount St. Helens National Monument, a Field Range Technician in the Deschutes National Forest, and a Recreation Specialist on the Inyo, Tahoe, and Mount Baker-Snoqualmie National Forests. In these positions, I witnessed firsthand how roadless areas serve as critical ecological refuges, recreational havens, and sources of clean water and air for millions of Americans. The proposed rescission of the 2001 Roadless Area Conservation Rule is a dangerous step backward that would undermine decades of progress in protecting these irreplaceable lands. This rule has been upheld by courts, supported by science, and cherished by the public—and it must not be weakened. Key Concerns Loss of Protections for Roadless Areas The 2001 Roadless Rule currently protects 58.5 million acres of inventoried roadless areas from road construction, road reconstruction, and timber harvesting. Rescinding this rule would open these lands to industrial exploitation, fragmenting habitats, degrading water quality, and diminishing recreational opportunities. Source: USDA Forest Service: Proposed Rule to Rescind the 2001 Roadless Rule (2026) Local Decision-Making ≠ Better Outcomes The proposal claims that returning decisionmaking to local Forest Service officials will improve management. However, local priorities are often driven by short-term economic interests (e.g., logging, mining, or development) rather than long-term ecological sustainability. The 2001 Roadless Rule ensured consistency across all national forests, preventing a patchwork of protections. Source: Western Priorities: “The Forest Service’s own review finds repealing the Roadless Rule could increase wildfire risk and harm communities” (Aug 21, 2026) Public Lands Are a Public Trust National forests belong to all Americans, not just local interests. The 2001 Roadless Rule was developed through extensive public input and has been upheld by courts (e.g., California ex rel. Lockyer v. U.S. Department of Agriculture, 575 F.3d 999 (9th Cir. 2009)). Rescinding it silences the voices of millions of outdoor enthusiasts, scientists, and communities who value these lands for their recreational, ecological, and cultural significance. Source: Selc.org: “U.S. Forest Service seeks to slash public input on public lands” (Feb 11, 2026) Increased Wildfire Risk The Forest Service’s own review acknowledges that repealing the Roadless Rule could increase wildfire risk by allowing more road construction and logging in sensitive areas. Roadless areas act as natural firebreaks and carbon sinks, and their degradation would exacerbate climate change impacts. Source: Western Priorities: “The Forest Service’s own review finds repealing the Roadless Rule could increase wildfire risk and harm communities” (Aug 21, 2026) Erosion of Public Trust in the Forest Service As a former employee, I saw how public trust in the Forest Service is built on transparency, science, and accountability. This proposal abandons those principles in favor of regulatory rollbacks that prioritize industry over people and the planet. The Forest Service must listen to the public, not corporate interests. Request to the USDA and Forest Service Withdraw the proposed rescission of the 2001 Roadless Area Conservation Rule. Extend the public comment period beyond September 21, 2026, to allow for meaningful engagement from scientists, Tribes, outdoor enthusiasts, and communities. Reaffirm the agency’s commitment to protecting roadless areas as critical components of our national forest system. Conduct a new environmental impact statement that fully evaluates the ecological, recreational, and economic costs of rescinding the rule. The 2001 Roadless Rule is a cornerstone of conservation in the United States. Rescinding it would set a dangerous precedent and weaken protections for some of our most pristine landscapes. I urge the USDA and Forest Service to reject this proposal and instead strengthen protections for roadless areas. Sincerely, Former Forest Service Employee

I am a rock climber, whitewater kayaker, angler, hiker, mountain biker, hunter, and equestrian who uses inventoried roadless areas constantly, and I do volunteer trail work myself. I also have a friend whose primary job is conducting professional fishery surveys on rivers like the Colorado, and another friend who works for the U.S. Geological Survey doing sonar-based hydrographic surveys — work that depends directly on the low-sediment water conditions this rule would put at risk. This rule guts the resource all of that depends on, and it should be withdrawn. USDA's own numbers admit near-term timber gains would be "modest and localized," yet the rule could impose over $100 million/year in net costs, including $6.1 million annually in lost recreation value — while the agency already carries a $6.9 billion road/bridge maintenance backlog it can't fund. You're proposing to build more roads you already can't maintain, to chase benefits you can't quantify. That's not policy, it's vandalism with a cost-benefit annex. This isn't a close legal call. USDA's rationale — that NFMA forest-level planning, not a national rule, is the right vehicle here — is the exact argument Wyoming made trying to kill this rule, and the exact argument the Tenth Circuit rejected in Wyoming v. USDA, 661 F.3d 1209 (10th Cir. 2011), holding nothing in NFMA "precludes national action on a conservation issue within the power of the Forest Service," and reinstating the Rule nationwide. Kootenai Tribe v. Veneman, 313 F.3d 1094 (9th Cir. 2002), and California ex rel. Lockyer v. USDA, 575 F.3d 999 (9th Cir. 2009), went the same way. USDA is relitigating a theory that has already lost twice. Under State Farm, 463 U.S. 29 (1983), and Encino Motorcars v. Navarro, 579 U.S. 211 (2016), an agency reversing a 25-year policy with entrenched reliance interests owes a "more detailed justification," not less. USDA's own preamble instead asks commenters to do its reliance analysis for it. That is precisely the abdication those cases forbid. Roadless watersheds supply drinking water to roughly 25 million Americans (PLOS Water, 2026) — over a third of Colorado's and New Mexico's populations. An onX analysis found 99% of Wyoming's roadless acreage functions as elk security habitat, the exact kind of low-road-density cover big game and Pittman-Robertson-funded wildlife management depend on. Roads and logging degrade the cold, clean headwaters that trout, salmon, and steelhead need, undermining Clean Water Act antidegradation protections (40 CFR §131.12) and, for anadromous fisheries, Magnuson-Stevens Essential Fish Habitat obligations. Whitewater and scenic values on Wild and Scenic-eligible rivers running through these areas are equally at risk. The wildfire justification doesn't hold up either: risk to communities is concentrated in the wildland-urban interface, which the agency can already treat under existing exceptions, not in remote backcountry this rule would newly expose to roads. USDA's own notice admits the "majority sentiment among Tribal governments consulted is opposition," citing threats to sacred sites, subsistence resources, and treaty rights, and admits a failure to fulfill trust and consultation obligations — obligations that carry the "highest responsibility and trust," Seminole Nation v. United States, 316 U.S. 286 (1942). ANILCA §810 requires a subsistence evaluation before, not after, action in Alaska. And procedurally: this comment period is 30 days with zero public hearings, following a truncated 21-day notice period on which 99% of 220,000+ comment letters opposed rescission. The 2001 Rule was built on 600+ hearings and 1.6 million comments. That is not a good-faith effort to hear from the public — it's a box-checking exercise on the way to a predetermined outcome. Withdraw this rule. If site-specific flexibility is genuinely needed, the existing state-petition process (5 U.S.C. §553(e); 7 CFR 1.28) already used by Idaho and Colorado is the right tool — not eliminating baseline protection for 44.7 million acres of the last big wild country left in the National Forest System. Full legal analysis, additional statutory citations (Wild and Scenic Rivers Act, Clean Water Act, Magnuson-Stevens Act, Pittman-Robertson Act, National Trails System Act, NEPA, ESA), and complete source list are provided in the attached comment letter, which I incorporate by reference.

PUBLIC COMMENT RE: Docket No. FS–2025–0001; RIN 0596–AD66 Special Areas; Roadless Area Conservation — Proposed Rescission of the 2001 Roadless Area Conservation Rule** Submitted to: Federal eRulemaking Portal, https://www.regulations.gov Submitted by: Julie Stoner Date: September 16, 2026 I'm writing to urge USDA to exclude the Tongass National Forest from any rescission of the 2001 Roadless Area Conservation Rule. USDA justifies this rescission by pointing to drought, wildfire, and insect/disease risks concentrated in Western forests. The Tongass is a temperate coastal rainforest, not a fire-prone Western forest — the rationale simply doesn't apply. Before any rule change affects the Tongass, USDA should have to show forest-specific data proving otherwise. This rescission's reach is enormous: it would strip protection from nearly all 58.5 million acres covered by the 2001 Rule, opening up to 18.2 million acres to road construction and 4.8 million acres to expanded logging nationwide — effects far beyond where the stated wildfire rationale even makes sense. The Tongass carries real, documented reliance interests: its old-growth stands are a major carbon sink, it sustains bald eagle and wildlife habitat, and its salmon-bearing watersheds are central to Tribal and Alaska Native subsistence, food security, and culture. USDA's own consultation record shows most Tribal governments opposed this rescission, citing threats to sovereignty and inadequate government-to-government consultation. That opposition deserves real weight, and a full ANILCA Section 810 subsistence analysis is owed before any decision affecting the Tongass moves forward. This also isn't the first attempt to unwind roadless protections — the 2001 Rule survived exactly this kind of rollback once already, in litigation culminating in the Ninth Circuit's 2009 decision in (California ex rel. Lockyer v. USDA 575 F.3d 999). A rushed, one-size-fits-all rescission is likely to end up back in court. I'm asking USDA to: - Exclude the Tongass from any final rescission, or adopt a Tongass-specific framework built on Tribal co-stewardship and Traditional Ecological Knowledge (e.g., the "Strengthened Roadless Rule Alternative"). - Complete a full ANILCA Section 810 subsistence analysis for the Tongass before finalizing any rule affecting it. - Provide Tongass-specific data justifying the wildfire/forest-health rationale, or drop it. - Give substantial weight to the Tribal governments' documented opposition. - Conduct forest-specific analysis for other significantly affected forests, rather than one blanket nationwide justification. Thank you for considering my comment. Julie Stoner Sagaponack, New York

I submit this comment in opposition to the proposed rescission as applied to the White Mountain National Forest (NH/ME, ~368,000 acres of inventoried roadless area, including the Kilkenny, Pemigewasset, Sandwich Range, and Wild River units) and the Green Mountain National Forest (VT, ~80,000 acres of roadless land outside designated wilderness). I am a civilian without a legal background but here is what I understand to be true: Under the Administrative Procedure Act, 5 U.S.C. § 706(2)(A), and Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29 (1983), an agency rule is arbitrary and capricious where the agency fails to examine relevant data, offers an explanation that runs counter to the evidence before it, or fails to consider an important aspect of the problem. USDA’s stated rationale for this rescission is centered on wildfire risk reduction and fuels management, yet the agency has provided no region-specific finding that this rationale applies to the low-fire-risk forests of the Northeast. A single national rationale applied without differentiation to ecologically and climatically distinct regions is precisely the kind of unreasoned, one-size-fits-all action the arbitrary-and-capricious standard is designed to prevent. Notably, USDA has already demonstrated that regional tailoring of roadless management is both administratively workable and consistent with the agency’s obligations: the Idaho Roadless Rule (2008, ~9.3 million acres) and Colorado Roadless Rule (2012, ~4.2 million acres) remain in effect and are expressly excluded from this very rulemaking. The agency’s own proposal therefore establishes that a national, undifferentiated rescission is not the only reasonable course available — and under NEPA’s requirement to consider a reasonable range of alternatives, 42 U.S.C. § 4332(2)(C); 40 C.F.R. § 1502.14, along with the precedent set in Lockyer v. USDA, 575 F.3d 999 (9th Cir. 2009), which USDA itself cites in this proposal, I request that the agency either withdraw the rescission as to the White Mountain and Green Mountain National Forests or formally analyze and respond to a New England-specific alternative in the final EIS and rule, consistent with the state-specific approach already adopted for Idaho and Colorado. I ask that this comment, including the specific alternative requested, be entered into the administrative record and addressed in USDA’s response to comments.

I am writing to oppose rescission of 36 C.F.R. part 294, subpart B as proposed. The Department should identify what the rule prevents before removing it. 1. THE RULE ALREADY AUTHORIZES THE WORK THE NOTICE SAYS IT NEEDS The stated need is wildfire, insects, disease, and community protection. Subpart B permits each. Section 294.13(b)(1)(ii) authorizes cutting and removal of generally small diameter timber "to maintain or restore the characteristics of ecosystem composition and structure, such as to reduce the risk of uncharacteristic wildfire effects" -- the notice's own rationale, already in force. Section 294.12(b)(1) authorizes roads needed against an imminent threat of flood, fire, or other catastrophic event; (b)(2)-(7) cover response actions, reserved rights, realignment, safety, and pre-2001 leases; 294.12(c) permits road maintenance. The rule restricts road construction and timber cutting; it does not restrict fire suppression at all. Congress layered more on top. HFRA, 16 U.S.C. 6512, reaches wildland-urban interface land, municipal watersheds, and land threatened by "an epidemic of disease or insects," and its (d) exclusions do not reach roadless areas. Insect and disease designations under 6591a, with the exclusions at 6591b, 6591d and 6591e, add expedited authority. None of it requires rescission. REQUEST: identify, by unit, year, and acreage, every fuels, insect and disease, or hazard-tree project the Forest Service declined to propose or could not approve solely because of 294.12 or 294.13, and explain why 294.13(b)(1)(ii) was insufficient. The notice has no such list. Without one, the need is unsupported. 2. THE MEANS ARE NOT MATCHED TO THE STATED END The notice reports 9.8 million acres of wildland-urban interface overlap and 18.2 million acres where plans would permit permanent roads. It removes the prohibition across all of it, not the acreage where the stated risk is documented. A rescission scoped to documented risk would serve the stated purpose. This one reaches further. The record also points elsewhere for cause. Acres treated for wildfire risk fell from roughly 4.1 million in FY2024 to roughly 2.6 million in FY2025 -- 35 percent, with the rule unchanged in both years -- amid the loss of roughly 5,000 staff. Rescission adds no crews and no appropriations. If the constraint is workforce, a rule change cannot relieve it. 3. THE EXECUTIVE ORDERS ARE NARROWER THAN THE USE MADE OF THEM E.O. 14153 section 3(c), 90 Fed. Reg. 8351, directs the Secretary to address the 2023 Alaska Roadless Rule and reinstate the 2020 Alaska rule. It is Alaska-specific on its face and cannot support a nationwide rescission reaching some 45 million acres -- 58.5 million less the retained Idaho and Colorado rules (9.3M and 4.2M). More fundamentally, each cited order states that it creates no right or benefit enforceable at law and is to be implemented consistent with applicable law. That clause cuts both ways: it defeats a challenge to the orders, and equally defeats any suggestion that the Department was compelled. Authority over National Forest System lands is delegated by statute. An order may direct how the Secretary exercises discretion; it cannot enlarge it or substitute for the findings NFMA and MUSYA require. See also 16 U.S.C. 531(a): multiple use does not mean the combination of uses giving "the greatest dollar return or the greatest unit output." 4. THE DEPARTMENT ALREADY BUILT THE ALTERNATIVE Subparts C and D answer the notice's own premise. Idaho's management themes and Colorado's upper-tier structure deliver graduated, place-based flexibility -- community protection zone treatment, temporary road authority -- inside a retained roadless rule. Both have stood since 2008 and 2012, and are being kept. Explain why that model cannot be extended, and why targeted amendments to 294.12 and 294.13, drawn from 294.42-.43, were not analyzed. 5. REQUESTS FOR THE RECORD a. State whether ESA section 7 consultation on this rescission has been initiated, with whom, and when. Lockyer v. USDA, 575 F.3d 999 (9th Cir. 2009), set aside the identical 2005 repeal for failing to consult before effecting it. This notice mentions the Act once, in a savings clause. b. Publish the models behind the harvest, revenue, and recreation figures, or omit them from any final rule; data relied on must be exposed to comment. State the "potentially affected environment" acreage and reconcile it to 58.5M, or another figure as apporpirate. c. Place the ANILCA section 810 evaluation, notice, hearing, and findings inside the EIS, as 16 U.S.C. 3120(b) requires. d. Add monitoring, reporting on acres roaded, and a scheduled reassessment -- rescission is reversible on paper; installed roads are virtually irreversible. Thank you for your service to the People of the United States.

To the Director, I am writing to formally oppose the U.S. Department of Agriculture's proposed rule to rescind the 2001 Roadless Area Conservation Rule (36 CFR Part 294, Subpart B), as published in the Federal Register on August 20, 2026 (91 FR 53827; RIN 0596-AD66). The 2001 Roadless Rule has protected 58.5 million acres of inventoried roadless areas across the National Forest System for a quarter century. It has survived extensive litigation, including affirmation by the Ninth Circuit in California ex rel. Lockyer v. U.S. Department of Agriculture, precisely because it reflects a durable, congressionally supported judgment that these lands merit protection from road construction, road reconstruction, and timber harvesting. Rescinding it now would eliminate that protection nationwide, replacing a single enforceable standard with a patchwork of local land management plans that can be amended or revised at the discretion of individual forest supervisors and regional foresters. I object to this proposal for the following reasons: Rescission removes a durable, national-level safeguard in favor of local discretion that can shift over time. The proposed rule acknowledges that governing land management plans "could still include restrictions" on road building and timber harvest in roadless areas, but that is not the same as a guarantee. Local plans are more susceptible to political and budgetary pressure, and can be amended without the level of national scrutiny the 2001 Rule provided. A protection that depends entirely on discretionary, unit-by-unit decisions is not a comparable substitute. The proposal's own analysis acknowledges significant costs. According to the Department's own cost-benefit estimates, the rule could result in over $100 million in additional annual economic effects, including an estimated $6.1 million in annual losses to recreation-based economic benefit, alongside temporary and long-term impacts to quiet, remote, and self-reliant recreation opportunities that roadless areas currently provide. Tribal opposition to this rescission has been substantial and should weigh heavily in the Department's decision. The Department's own supplementary information states that the majority of Tribal governments consulted oppose the rescission, viewing it as a threat to Tribal sovereignty, cultural survival, and the ecological health of ancestral homelands, and have raised concerns about inadequate government-to-government consultation. I urge USDA to give this opposition serious weight rather than proceeding on the current timeline. Roadless areas provide ecological value that a rescission puts at risk. These lands serve as some of the last large, unfragmented forest landscapes in the country, providing habitat for sensitive and at-risk species, protecting sources of public drinking water, and serving as carbon sinks. Increased road construction and vegetation management in these areas, even where localized, fragments habitat and increases sediment and pollutant loads into watersheds that both wildlife and downstream communities depend on. The stated rationale — reducing wildfire risk and regulatory burden — does not require wholesale rescission. If the Department's concern is genuinely about targeted fuel treatment near communities and the wildland-urban interface, that goal can be pursued through narrower, more targeted exceptions to the existing rule rather than eliminating national-level protection for all 58.5 million acres. A blanket rescission is a far broader remedy than the problem identified. For these reasons, I urge USDA to withdraw this proposed rule and retain the 2001 Roadless Area Conservation Rule in its current form. At minimum, I urge the Department to complete meaningful, comprehensive Tribal consultation before proceeding further, and to consider narrower alternatives — such as a Strengthened Roadless Rule Alternative incorporating Tribal co-stewardship, as raised during consultation — rather than a full national rescission. Thank you for considering this comment as part of the public record for this rulemaking. Sincerely, Nathan Page Morro Bay, CA

I am submitting this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR Part 294, Subpart B). My objections are based on the economic, procedural, and legal record contained within the proposed rule and its supporting materials, which I believe undermine rather than support the case for rescission. A. The Department's own cost-benefit data do not support the proposed action The Department states that the additional economic effects of rescission "could exceed $100 million" annually, while its own projected benefits are substantially smaller and less certain. The proposal estimates $5.2 to $11.4 million per year in incremental Treasury and Forest Service revenue, and $4.6 to $10.6 million per year in revenue to the timber industry, contingent on assumptions the Department itself calls unlikely to hold given "budgets, unforeseen limits on operability, and market conditions." Set against this, the Department projects a $6.1 million annual loss to recreation-dependent businesses alone, without a comparable dollar estimate for effects on commercial fishing, drinking water systems, or long-term ecosystem services. A rule expected to impose costs an order of magnitude larger than its most optimistic quantified benefits does not meet the standard of reasoned rulemaking required under Executive Order 12866, which the Department itself invokes as governing this action. I request that the final rule not proceed until the Department reconciles this asymmetry or provides a benefit estimate that can plausibly offset the projected costs. B. The wildfire rationale is internally inconsistent The proposal cites wildfire risk reduction as a central justification for rescission, yet the Department's own summary of impacts acknowledges that "greater public access can increase human-caused ignition potential in some locations." Independent research on fire ignition sources has consistently found that human-caused ignitions correlate with road density and access, which is consistent with the Department's own admission here. Additionally, the 2001 Rule already contains exceptions permitting fuel-reduction and forest-health activities without new road construction; the proposal does not explain why those existing exceptions are insufficient, nor does it quantify how much of the wildfire benefit claimed for rescission could be achieved without full repeal. I request that the Department provide an analysis isolating the wildfire-risk benefit attributable specifically to new road construction and timber harvest, as distinct from the benefit already available under the current rule's exception process. C. The land management planning process is not a demonstrated substitute for a national standard The proposal asserts that local land management plans can achieve "similar conservation objectives" to the 2001 Rule, but the rule text itself confirms this outcome is discretionary rather than assured: individual plans "could still include restrictions," and rescission "does not... compel" any particular plan outcome. This means the durability of roadless-area protection would vary by forest unit and could shift with each plan revision, creating exactly the kind of inconsistency and litigation risk that motivated the original 2001 national rule. Given that the 2001 Rule was itself the product of extensive litigation — including a Ninth Circuit affirmation in *California ex rel. Lockyer v. USDA*, 575 F.3d 999 (9th Cir. 2009) — replacing a litigated national standard with 100+ discretionary, revisable local plans is likely to generate a comparable or greater volume of legal challenges, undermining the Department's stated goal of reducing administrative burden. D. Tribal consultation findings documented in the proposal itself raise unresolved E.O. 13175 concerns The Department's own Tribal Input Received section states that the "majority sentiment among Tribal governments consulted is opposition to the proposed rescission," citing concerns that the Department has proceeded "without adequate government-to-government consultation" in fulfillment of its trust responsibilities. The Department separately determined that this rulemaking "would have substantial direct effects on Indian Tribes" sufficient to trigger E.O. 13175 consultation obligations. Given that only 29 of 64 requested consultations had been completed as of publication, I request that the Department complete the consultation process and incorporate its results into the rule before finalizing any decision, consistent with the Department's own determination that consultation is required here. I urge the Department to withdraw the proposed rescission, or at minimum to address the analytical gaps identified above before proceeding to a final rule. Respectfully submitted.