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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 strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule as proposed in the Special Areas: Roadless Area Conservation, 91 Fed. Reg 53827 (Aug. 20, 2026). See Attachment. 1. Preservation of Habitat and Ecosystem for Survival of Species Building roads in wilderness areas significantly impairs the ability of endangered and threatened species to survive by destroying the trees (logging), plants and habitat upon which so many species depend for sheltering, breeding or feeding. Habitat loss and degradation is the number one threat to survival of species. The Endangered Species Act (ESA) and its regulations have recognized this reality for over five decades. The Forest Service’s own analysis found that Alternative 2 would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats. 2. Preservation of water supplies Rescission of the Roadless Rule could harm the water supply for 25 million people (according to a University of Washington study that examined 2500 roadless areas). Logging roads threaten the ability of the watershed to provide clean, reliable water. 3. Increased Fire Risk and Lack of Funding & Staff to Maintain Backcountry forests are at 4 times greater risk of forest fires when roads and logging are introduced. 4. Preservation of wilderness for future generations Don’t tear up everything in one administration. Save some land and resources for the future!

Comment in Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule Special Areas; Roadless Area Conservation, 91 Fed. Reg. 53827 (Aug. 20, 2026); RIN 0596-AD66; Docket FS-2025-0001, including the Draft EIS (DEIS) I urge the Department to withdraw the proposed rule and select Alternative 1 (No Action). The Department's own proposal and DEIS do not show that rescission would meaningfully reduce wildfire risk, and they document harm to species, water, and old forest. Secondly this seems like a Full research attatched.

Dear USFS: Below are my comments on Proposed Rule—“Special Areas; Roadless Area Conservation,” 91 Fed. Reg. 53827 (Aug. 20, 2026), RIN 0596-AD66, Docket FS-2025-000 subpart D). I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR part 294, subpart B) for all Roadless Areas and urge the Forest Service to withdraw the proposal. I have read the Proposed Rule several times and find that it does not adequately demonstrate that rescission is necessary. As proposed, local land-management plans would not provide equivalent protection. The environmental consequences to wildlife, solitude, erosion, and fire control (to name a few) have not been fully evaluated. This letter addresses the Rough Creek Roadless Area, an approximately 8,476 -acre inventoried roadless area in the Humboldt-Toiyabe Natl Forest, Mono County, California. The Purpose and Need for Action in 91 Fed. Reg. 53827 (Aug. 20, 2026), RIN 0596-AD66, Docket FS-2025-000 subpart D).includes management flexibility … to respond to changing and localized conditions such as increasing wildfire risk” (see: https://www.federalregister.gov/documents/2026/08/20/2026-16965/special-areas-roadless-area-conservation) and increase logging and “access for minerals or energy uses” ” (see: https://www.federalregister.gov/documents/2026/08/20/2026-16965/special-areas-roadless-area-conservation) (printed page 53828). Woodlands in the Rough Creek Roadless Area (ERA) consist primarily of Pinyon Pine. I have taken multiple all day hikes into this roadless area. It is very beautiful and wild. Copses of Aspen. Pronghorns. It is a critical area for the Bi-state Sage grouse. It has incredible views of the Sierra Nevada. Punching in roads to decrease wildfire risk across the Rough Creek Roadless Area would be counter effective and increase the chance of fire ignition as many “fire builder” people like to camp and recreate in this area. A Biological Opinion--addressing all species affected by 91 Fed. Reg. 53827 (Aug. 20, 2026), RIN 0596-AD66, Docket FS-2025-000 subpart D)-- needs to be prepared. Repealing the Roadless Rule would be a calamity for many endangered and sensitive species. Species of concern with potential to occur in the Rough Creek Roadless Area include Pinyon Jay (Federal Register Document Number 2023-17726) (data and arguments to list the species as endangered or threatened present substantial scientific or commercial information indicating that the petitioned actions may be warranted), and possibly Bi-state Sage Grouse (USFWS is reopening consideration of whether to list the species as endangered or threatened). There is at least one record of Pinyon Jay in Rough Creek (EBird record for June 30, 2006 submitted by Sacha Heath). Bi-state Sage Grouse have been confirmed nearby. One of my hikes into Rough Creek was from the headwaters down along the creek for about 3 miles. The attraction for me was that it was roadless! The Bodie Hills have an unparalleled wild beauty – snowcapped peaks and ruling sagebrush ocean. No roads are needed beyond what are already present in Rough Creek. Any new roads would be in very steep country and be highly subject to erosion. Any attempt to repeal the roadless act must take into full consideration the watershed, fisheries, and wildlife. The Rough Creek Roadless Area provides exceptional opportunities for wildlife, solitude, adventure, and pride in being an American – a kind of pride that us Americans had/have the red, white, and blue foresight to protect opportunities for exploration and enjoyment of areas with no roads. This is our wild heritage. Being able to explore roadless areas on foot or horseback or mule back is an American right. We do NOT want to share all roadless areas with wheeled conveyences, bikes, or motorized vehicles. Keep it roadless. Thank you, Emilie Strauss

Re: Docket FS-2025-0001 / RIN 0596-AD66 Special Areas; Roadless Area Conservation 91 Fed. Reg. 53827 (August 20, 2026) Document No. 2026-16965 To the U.S. Department of Agriculture and U.S. Forest Service:

See attached file(s) I submit the attached comment as a private citizen in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket No. FS-2025-0001, RIN 0596-AD66, 91 Fed. Reg. 53827 (August 20, 2026). I urge the Department to withdraw the proposal and retain 36 CFR part 294, subpart B under the No Action alternative. The attached document relies primarily on the Department's own preamble. It shows that the existing exceptions at §§ 294.12(b)(1) and 294.13(b)(1)(ii) already permit fuels reduction and emergency road access, and that the Ninth Circuit upheld use of the fuels exception on the Los Padres National Forest in 2024. The Department concedes that new road access can increase human-caused ignitions but has not quantified the net wildfire effect. Its projected timber revenue of $5.2 to $11.4 million per year depends on harvest levels it calls unlikely, while it estimates $6.1 million in annual recreation losses and reports a $6.9 billion road maintenance backlog. Current forest plans would permit permanent roads on about 18.2 million acres, or 45.5 percent of the affected area, which contradicts the claim that plans provide equivalent protection. The attachment also addresses the Department's failure to justify its change in position and assess reliance interests under FCC v. Fox Television Stations and DHS v. Regents, incomplete Tribal consultation with majority Tribal opposition, a comment period shorter than the 60 days contemplated by Executive Order 12866, and an inconsistent preemption statement in the Civil Justice Reform section. It concludes with seven specific recommendations. I ask the Department to respond to each point in its response to comments.

I am writing regarding USDA’s proposal to rescind the 2001 Roadless Area Conservation Rule. The proposed rule would remove nationwide protections from approximately 44.7 million acres of national forest land, including areas in Alaska’s Tongass National Forest. Idaho and Colorado would remain governed by their separate state-specific rules. (91 Fed. Reg. 53827; Docket FS-2025-0001.) Although rescission would not authorize individual projects automatically, it would remove the national restrictions on road construction, road reconstruction, and timber harvesting. Future activities could proceed where forest plans allow and subsequent environmental reviews approve them. USDA estimates that rescission could expand timber-management opportunities across approximately 4.8 million acres. Before making a final decision, USDA should fully evaluate the cumulative effects of additional roads and logging on drinking-water watersheds, old-growth forests, wildlife habitat and connectivity, carbon storage, invasive species, recreation, and Tribal cultural resources. It should also address the financial implications of adding roads when the Forest Service already faces a multibillion-dollar road-and-bridge maintenance backlog. Wildfire claims also require careful scrutiny. The Forest Service’s environmental analysis reports substantially more human-caused ignitions on other national forest lands than in roadless areas and recognizes that increased access can increase ignition risks. The existing Roadless Rule also contains exceptions allowing certain work for ecological restoration, public safety, and wildfire-risk reduction. These forests provide clean water, wildlife habitat, carbon storage, and opportunities for hiking, fishing, camping, bicycling, skiing, climbing, and quiet recreation. Please ensure that the final decision gives these nationwide public benefits—and the potentially irreversible effects of fragmentation—the full weight they deserve. Sincerely, Tina Bailey

I am writing regarding USDA’s proposal to rescind the 2001 Roadless Area Conservation Rule. The proposed rule would remove nationwide protections from approximately 44.7 million acres of national forest land, including areas in Alaska’s Tongass National Forest. Idaho and Colorado would remain governed by their separate state-specific rules. (91 Fed. Reg. 53827; Docket FS-2025-0001.) Although rescission would not authorize individual projects automatically, it would remove the national restrictions on road construction, road reconstruction, and timber harvesting. Future activities could proceed where forest plans allow and subsequent environmental reviews approve them. USDA estimates that rescission could expand timber-management opportunities across approximately 4.8 million acres. Before making a final decision, USDA should fully evaluate the cumulative effects of additional roads and logging on drinking-water watersheds, old-growth forests, wildlife habitat and connectivity, carbon storage, invasive species, recreation, and Tribal cultural resources. It should also address the financial implications of adding roads when the Forest Service already faces a multibillion-dollar road-and-bridge maintenance backlog. Wildfire claims also require careful scrutiny. The Forest Service’s environmental analysis reports substantially more human-caused ignitions on other national forest lands than in roadless areas and recognizes that increased access can increase ignition risks. The existing Roadless Rule also contains exceptions allowing certain work for ecological restoration, public safety, and wildfire-risk reduction. These forests provide clean water, wildlife habitat, carbon storage, and opportunities for hiking, fishing, camping, bicycling, skiing, climbing, and quiet recreation. Please ensure that the final decision gives these nationwide public benefits—and the potentially irreversible effects of fragmentation—the full weight they deserve.

This is to say that I OPPOSE the August 20,2026, 91 Fed. Reg. 53827 "Special Areas: Roadless Area Conservation " proposed rule rescinding the 2001 Roadless Rule, 36 CFR Park 294. The USDA Forest Service has not provided a detailed justification for the new policy and the new policy rests upon findings that contradict the evidence supporting its prior rule (the 2001 Roadless Rule). Per the USDA Forest Services own examination in 2020 of the forest health implications of roadlessness, evidence determined that building roads through the forests INCREASES the number of wildfires. This contradicts the USDA Forest Service's unsubstantiated justification (minimizing wildfires) for the recission. Elsewhere, in a separate three decade study published in Fire Ecology in 2026, results showed that building roads into roadless areas is likely to result in MORE fires. Both the 2020 USDA Forest Service Study and the 2026 Fire Ecology study found higher rates of fire ignition near roads, resulting in an increased number of wildfires . In addition, the 2020 Forest Service study determined that roadless areas benefit from greater fuel management per square kilometer than elsewhere in the forest system, also contradicting the proposed rule’s unsubstantiated justification of greater access for forest management. The proposed rule is arbitrary and capricious because the new policy rests upon factual findings that contradict those which underlie its prior policy. Therefore, since there has been no new scientific evidence or justification provided by the USDA Forest Service to support the recission, the proposed rule should be withdrawn.

Re: Public Comment on Proposed Rule: Special Areas; Roadless Area Conservation (91 FR 53827, Docket ID: FS-2025-0001, RIN 0596-AD66) I am writing to express strong opposition to the proposed rule to rescind the 2001 Roadless Area Conservation Rule across National Forest System lands. My detailed substantive comments are set forth in full in the attached PDF document ("Comment on Proposed Rule Special Areas Roadless Area Conservation.pdf"). In summary, this is to respectfully say that the USDA Forest Service justification for proposed rule “Special Areas; Roadless Area Conservation,” August 20, 2026, 91 Fed. Reg. 53827, which would rescind the 2001 Roadless Rule, 36 CFR Part 294, is in direct conflict with the USDA Forest Service’s own research and it is also in conflict with InForm Fire Occurrence Data Records 1992 to 2024. The USDA Forest Service does not address these conflicts in its record. Accordingly, the proposed rule should be withdrawn.

National Federation of Independent Business (NFIB) comment letter in response to U.S. Forest Service/USDA notice of proposed rulemaking titled "Special Areas; Roadless Area Conservation," RIN 0596-AD66, 91 Fed. Reg. 53827 (August 20, 2026), is attached.

RE: Docket No. FS-2025-0001 / RIN 0596-AD66 — Proposed Rescission of the 2001 Roadless Area Conservation Rule I oppose rescission of the 2001 Roadless Area Conservation Rule and ask USDA to retain its national protections, using targeted exceptions only where a site-specific, science-based need is demonstrated. USDA says rescission would reduce regulatory burden, return roadless-area decisions to individual forests, and increase flexibility for wildfire, forest health, timber, and other management. But flexibility alone does not justify eliminating a nationwide conservation standard. The Federal Register notice confirms that rescission would remove national restrictions on road construction, road reconstruction, and timber harvest in inventoried roadless areas. Federal Register, Special Areas; Roadless Area Conservation, 91 Fed. Reg. 53827 (Aug. 20, 2026); Regulations.gov docket FS-2025-0001. I live in Oregon and spend substantial time hiking off-trail, hunting, fishing, and exploring remote public lands, including in Alaska. My firsthand experience is that intact roadless landscapes have a different ecological character than places shaped by permanent road networks: complex forest structure, intact riparian vegetation, abundant wildlife, clean water, and fewer cumulative impacts. Roads affect far more than the ground they occupy. They create lasting pathways for erosion, sediment delivery, stream crossings, habitat fragmentation, invasive species, human-caused ignitions, and future development. Once roads enter an intact watershed, many effects are difficult or impossible to reverse. A 2026 PLOS Water analysis found that inventoried roadless areas protect more than 80,000 miles of rivers and streams in the conterminous United States, and that nearly 62,000 miles rely on the Roadless Rule as their primary protection. Watersheds influenced by roadless areas supply drinking water to about 25 million people. Olden, Postel, Dombeck, Kesting, Freeman, & Comte (2026), Assessing the value of the U.S. Roadless Rule for people and nature, PLOS Water, 5(7), e0000538. https://doi.org/10.1371/journal.pwat.0000538. Wildfire risk is real in Central Oregon, but wildfire policy should be evidence-based. Aplet, Hartger, and Dietz found national forest ignition density of 1.75 fires per 1,000 hectares in wilderness, 1.97 in inventoried roadless areas, 3.50 on other national forest lands, and 7.99 within 50 meters of roads. Human-caused ignition density exceeded 3.5 fires per 1,000 hectares within 250 meters of roads, compared with fewer than 0.5 more than 2 kilometers from roads. Aplet, Hartger, & Dietz (2026), Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads, Fire Ecology, 22, Article 8. https://doi.org/10.1186/s42408-026-00450-2. Roads can provide suppression access, and the rule already allows tailored exceptions where justified. The evidence does not support using wildfire as a basis for wholesale rescission. If new roads can increase ignition risk while damaging watersheds, USDA must explain why narrower tools are inadequate before eliminating national protections. USDA should account for benefits that would be lost, not only opportunities created. Rescission would make new roadbuilding and harvest easier where they are now limited, with costs to quiet recreation, sediment control, habitat continuity, drinking water, carbon storage, biodiversity, and roadless character. USDA itself estimates approximately $6.1 million annually in lost recreational economic benefit in affected areas, while projected timber-related revenues are limited and uncertain. Before rescinding the Roadless Rule, USDA should demonstrate that repeal would provide equal or greater protection for watershed integrity, aquatic habitat, drinking-water sources, biodiversity, recreation, and wildfire resilience. The current record does not make that showing. Instead, it shows that national roadless protections provide measurable public benefits and that some losses from new roads and development would be difficult or impossible to repair. For these reasons, I respectfully request that USDA withdraw the proposed rescission and retain the 2001 Roadless Area Conservation Rule. Where legitimate management needs exist, USDA should use existing exceptions, site-specific authorities, or narrowly tailored amendments rather than eliminate a nationwide conservation standard across tens of millions of acres. In its final decision, USDA should directly address the peer-reviewed evidence on roads, wildfire ignitions, watershed protection, drinking water, and the loss of protections not duplicated by other management mechanisms. The burden should be on USDA to show that nationwide rescission is necessary and that the long-term public and ecological benefits clearly outweigh the costs. Thank you for your consideration.

I am writing in strong opposition to the U.S. Department of Agriculture’s proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service to retain the existing rule and select the No Action alternative. The Roadless Rule protects something increasingly rare: large, substantially undeveloped areas of our public lands. These landscapes provide wildlife habitat, protect watersheds, support hunting, fishing, hiking, and other recreation, and preserve opportunities for Americans to experience national forests without roads and industrial development. Once an intact roadless landscape is fragmented, its character and ecological value can be extraordinarily difficult to restore. USDA has not demonstrated that wholesale rescission is necessary to address the management concerns identified in the proposed rule. The existing Roadless Rule is not an absolute prohibition on responsible forest management. It contains exceptions and permits appropriate actions under specified circumstances. If particular provisions need modernization to address wildfire, public safety, or site-specific management concerns, USDA should consider targeted amendments rather than eliminate the national protection altogether. Several of USDA’s own findings weigh against rescission. The proposed rule acknowledges that permanent road construction could become permissible on approximately 18.2 million acres where current forest plans allow roads but the Roadless Rule currently prohibits them. It further identifies approximately 11.3 million acres where temporary roads may be more likely. 91 Fed. Reg. 53827, 53829 (Aug. 20, 2026). That is not a minor administrative change; it removes a nationwide conservation safeguard from millions of acres of public land. The economic rationale is also unconvincing. USDA acknowledges a $6.9 billion deferred-maintenance backlog for Forest Service roads and bridges and states that any timber-sale efficiency gains from rescission are expected to be incremental and limited by road costs and maintenance-funding gaps. Id. at 53829. Opening additional areas to road construction while the agency already faces billions of dollars in deferred road maintenance is poor fiscal and land-management policy. Wildfire does not justify blanket rescission either. USDA itself acknowledges that greater public access can increase the potential for human-caused ignitions. Id. There may be locations where strategically placed access or mechanical treatment is appropriate to protect communities and critical infrastructure. But that supports targeted, site-specific management—not elimination of protections across the national roadless system. The agency should explain why existing exceptions and narrower alternatives are insufficient before adopting the most sweeping alternative available. USDA also acknowledges tradeoffs to recreation, including effects on quiet, remote, and self-reliant recreation, and estimates approximately $6.1 million annually in lost economic benefits to recreationists. Id. at 53830. Those uses have real economic and public value and deserve serious consideration alongside potential timber revenues. Local management and national conservation standards are not mutually exclusive. The Roadless Rule establishes a national baseline while leaving the Forest Service substantial authority to manage individual forests. Rescission would remove that baseline and expose roadless areas to piecemeal decisions whose cumulative effects may be difficult or impossible to reverse. USDA also acknowledges that later amendments or revisions to individual forest plans could further increase the acreage where road construction and timber harvest are allowed. Id. The agency should also give substantial weight to the reliance interests that have developed during the Rule’s twenty-five years of operation. Recreationists, hunters, anglers, nearby communities, businesses, Tribes, conservation organizations, and individual Americans have relied on continued protection of these landscapes. For these reasons, I strongly oppose rescission of 36 C.F.R. Part 294, Subpart B. USDA should retain the 2001 Roadless Area Conservation Rule and select the No Action alternative. At minimum, it should reject wholesale rescission and consider targeted measures addressing demonstrated management needs while preserving nationwide protection for inventoried roadless areas. These lands belong to the American public, including future generations. There will always be pressure to build another road or extract another resource. There will not always be another opportunity to preserve an intact roadless landscape once it has been fragmented. Please retain the Roadless Rule.

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