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I strongly oppose the proposed rescission of the Roadless Rule. The proposal is legally and scientifically inadequate because it fails to justify abandoning long-standing protections that have safeguarded watersheds, wildlife habitat, recreation, ecosystem integrity, and climate resilience since 2001. The Forest Service should withdraw the proposed rescission or prepare a legally adequate analysis that fully evaluates the Roadless Rule’s continuing ecosystem- and wildfire-related benefits. 1. Arbitrary and Capricious Agency Action (Administrative Procedure Act) The Forest Service has not provided the reasoned explanation required by the Administrative Procedure Act for reversing a nationwide policy that has been implemented for more than two decades. The agency does not show that roadless protections are ineffective, identify changed conditions that eliminate the need for them, or address the evidence supporting their watershed, wildlife, recreation, and ecosystem benefits. Under FCC v. Fox Television Stations, Inc. (2009), an agency changing course must acknowledge and justify the change. 2. Inadequate NEPA Analysis USDA’s environmental review does not take the required hard look at the consequences of rescission. The analysis fails to adequately evaluate cumulative impacts from new roads and timber harvest, effects on wildlife, old-growth forests, watersheds, carbon storage, and climate resilience, reasonable alternatives to full rescission, and unsupported assumptions that road construction will reduce wildfire risk. 3. Conflict with National Forest Management Act (NFMA) The agency’s reliance on individual forest plans under NFMA is insufficient. NFMA requires maintenance of ecological integrity and multiple-use values at landscape scales, and forest-by-forest decisions may not protect roadless values consistently across the National Forest System. A national baseline better fulfills NFMA’s long-term conservation purposes. 4. Wildfire Rationale USDA’s wildfire rationale is unsupported. The existing Roadless Rule already allows many fuel-reduction activities, and the agency has not shown that rescission would materially reduce fire risk. New roads may instead increase human-caused ignitions, access-related disturbance, and long-term maintenance costs. Recent research shows ignition densities are far higher near roads than in wilderness or roadless areas, undermining the claim that more roads necessarily improve wildfire outcomes. 5. Endangered Species Act (ESA) The Roadless Rule provides important landscape-scale protection for listed species by maintaining large, connected, low-road-density habitats, movement corridors, and areas with reduced human disturbance. The Draft EIS must show that project-level ESA review would provide equivalent protection if the national rule is removed. 6. Scientific record and habitat connectivity The original Roadless Rule was based on extensive findings about habitat fragmentation, watershed protection, and ecosystem integrity. The Forest Service has not adequately explained why those findings no longer apply, particularly regarding road impacts on connectivity, sensitive and listed species, sedimentation, water quality, carbon storage, and climate adaptation. Road ecology literature identifies roads as major drivers of habitat fragmentation, wildlife mortality, impaired movement, and aquatic degradation. Studies have found that roadless areas fill gaps in the national conservation network, provide habitat for imperiled species, overlap with key biodiversity priorities, and support regional connectivity that is increasingly important as species respond to climate change. 7. Watershed protection and climate resilience Roadless areas provide clean water, intact watersheds, dispersed recreation, carbon storage, and climate resilience by limiting road-related erosion, sedimentation, fragmentation, and disturbance. The agency’s own 2000 EIS recognized these values, and the proposal does not provide evidence that they are no longer relevant. 8. Reliance Interests The Forest Service also failed to adequately consider reliance interests. States, tribes, local governments, recreation businesses, water agencies, conservation organizations, and the public have relied on roadless protections for more than 25 years. Before eliminating the rule, the agency must explain how it considered those interests, including recreation, clean water, backcountry character, and ecosystem services, as required by Department of Homeland Security v. Regents of the University of California (2020). 9. Public Trust and Watershed Protection Arguments The Forest Service has public responsibilities to protect municipal water supplies, intact watersheds, recreation opportunities, wildlife habitat, and backcountry values. The proposal gives insufficient weight to these public benefits and the costs of losing them.