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Re: Special Area; Roadless Area Conservation Docket No. FS-2025-0001 RIN 0596-AD66 I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule because its claimed wildfire management benefits do not justify the environmental, recreational, and fiscal costs. I am a native New Hampshirite and hike or backpack in the White Mountain National Forest (WMNF) once or twice a month. Some of its wildest areas - like Lincoln Woods, the Sandwich Range and Mount Chocorua, and areas surrounding the Pemigewasset Wilderness - lie within the 235,000 acres of Inventoried Roadless Areas (IRA) in the WMNF [1]. These landscapes help draw roughly six million people annually [2]. The rescission of the Rule places them at risk from commercial timber harvesting. I argue three points against this proposed rescission: 1. Wildfire Management Benefits are not Proportional to Environmental Risks The Rule already allows substantial wildfire risk management, so the Forest Service’s rationale that a full repeal is needed for wildfire mitigation is flawed. Under 36 C.F.R. § 294.13(b)(1), small-diameter timber may be cut or removed to maintain or restore ecosystems, including to “reduce the risk of uncharacteristic wildfire effects.” The Forest Service also stated that “hazardous fuels treatment in inventoried roadless areas is not prohibited by this rule, so long as road construction or reconstruction is not necessary.” 66 Fed. Reg. 3244, 3258 (Jan. 12, 2001). The Rule separately permits road construction when necessary to protect public health and safety from an imminent threat of fire or another catastrophic event. 36 C.F.R. § 294.12(b)(1). I concede that rescission would provide managers more flexibility, but that does not justify eliminating nationwide protections. New roads fragment habitat, increase erosion and sedimentation, and increase human access; the proposed rule itself acknowledges that “greater public access can increase human-caused ignition potential.” 91 Fed. Reg. 53829 (2026). If additional access is needed in particular high-risk forest, “especially in the Western United States,” the Forest Service should adopt targeted exceptions instead of repealing the Rule nationwide. 2. Harm to Scenic Value and Recreation Beyond environmental significance, the WMNF is the crown jewel among NH’s natural assets that support major tourism and outdoor recreation activity. This activity supports 30,000 jobs and contributes $4 billion to the state’s economy annually [2]. The Forest Service acknowledges that rescission could cause “noise, visible infrastructure, and temporary closures” and reduce opportunities for “quiet, remote and self-reliant recreation.” What’s more, the estimated $6.1 million in annual lost recreation is likely an underestimate because the analysis relies heavily on assumptions and admits substantial uncertainty about what and where development would actually occur. In a heavily visited forest like the WMNF, those losses deserve substantial weight. Commercial access that degrades remote landscapes should not be expanded absent a demonstrated public benefit. 3. New Roads are Difficult to Justify Amid a $6.9 Billion Maintenance Backlog The Forest Service already faces a multi-billion dollar backlog of deferred maintenance for its existing roads. 91 Fed. Reg. 53829. It acknowledges that timber harvest and vegetation management would likely create the greatest demand for new roads, and that expected timber-efficiency gains would be “incremental” and constrained by road costs, maintenance funding gaps, and the $6.9 billion backlog. It is fiscally irresponsible to open areas to taxpayer-funded road expansion for the benefit of private timber harvesters when the agency can’t afford to maintain existing infrastructure. Limited Forest Service resources would be better directed toward maintaining existing infrastructure than opening currently roadless lands to additional development. In sum, I request that USDA withdraw the proposed rescission and retain the 2001 Roadless Rule. If the agency concludes that additional management flexibility is necessary for wildfire risk reduction in particular regions or circumstances, it should pursue narrowly tailored amendments that preserve the Rule's nationwide baseline protection while addressing demonstrated management needs. Stripping all protections is an unnecessary excuse to open these delicate ecosystems to extractive industrial activities. [1] https://newhampshirebulletin.com/2026/09/14/repub/unique-stretch-of-new-england-forest-under-threat-after-proposed-rollback-of-roadless-rule/ [2] https://www.unh.edu/news/whos-visiting-new-hampshires-white-mountains

I live in East Tennessee near the Cherokee National Forest. I support active forest management, responsible timber use, and decisions that reflect real local conditions. I also believe local control requires enforceable guardrails, public notice, and accountability. For those reasons, I oppose Alternative 2 and the complete rescission of the 2001 Roadless Rule. USDA says this would return decision-making to the local level, but authority would not go to elected counties or states. It would give local federal officials more discretion while the public merely provides input. Removing the national floor and leaving residents to fight one plan amendment and project at a time is not meaningful local control. It shifts the oversight burden to the public. The scale conflicts with the description of near-term effects as “modest and localized.” Under current plans, rescission could expose about 18.2 million acres to permanent-road construction that the rule now prohibits. USDA also acknowledges a $6.9 billion deferred-maintenance backlog for roads and bridges and a possible $6.1 million annual loss in economic benefit to recreationists. Budget limits and current markets are forecasts, not safeguards. Plans and markets change. Judge this rule by the authority it creates, not only how quickly USDA predicts it will be used. See 91 Fed. Reg. 53829-53830. Wildfire and forest health are legitimate concerns, but full rescission is not the only answer. The current rule permits roads needed to protect public health and safety from an imminent threat of fire or another catastrophe. It also permits generally small-diameter timber removal for ecological restoration and reduction of uncharacteristic wildfire effects, plus incidental cutting for fire-line construction. See 36 CFR 294.12(b)(1) and 294.13(b)(1)-(2). If those approvals are inconsistent or too slow, USDA should repair that process instead of erasing the national standard. The Forest Service’s own research deserves a direct response. Sean P. Healey’s peer-reviewed 2020 study found similar burn rates in roaded and roadless forests, documented fuel treatments in roadless areas, and found non-native plants twice as common within 500 feet of roads. Nearly twenty years of monitoring did not support eliminating road prohibitions as a forest-health measure. DOI: https://doi.org/10.1088/1748-9326/aba031. The final EIS should explain with current evidence why USDA reaches a different conclusion. This is also a Tennessee issue. The Forest Service lists about 85,000 inventoried roadless acres out of 698,000 National Forest System acres in Tennessee. The base Cherokee National Forest plan was approved in 2004. Even with amendments, a plan more than twenty years old should not automatically be treated as an adequate substitute for the national rule. I ask USDA and the Forest Service to: 1. Select Alternative 1 and retain the rule unless and until a narrower replacement with enforceable protections is completed. 2. If added flexibility is needed, create defined, evidence-based procedures for hazardous-fuel and forest-health work, especially near the wildland-urban interface, instead of a blanket rescission. 3. Require every new road to have a documented need, life-cycle cost estimate, maintenance funding, water-quality controls, and enforceable decommissioning. Temporary roads must actually be temporary. 4. Publish a forest-by-forest gap analysis showing current protections, what each plan allows, and what changes under each alternative. Include clear maps and a specific analysis for Tennessee and the Cherokee National Forest. 5. Analyze cumulative and distributional effects, including sediment and drinking water, invasive species, human-caused ignition, wildlife fragmentation, recreation, tourism, and indirect effects on small rural businesses. No direct compliance duty does not mean no economic impact. 6. Complete Tribal consultation and Alaska subsistence analysis before choosing a final alternative, and require meaningful advance notice and comment before any plan or project removes roadless protections. I am not asking the Forest Service to ignore unhealthy conditions or prevent emergency work. I am asking it to act with precision, evidence, and public accountability. Roads and their costs can outlast the timber sale and the administration that approved them. Keep the national floor, improve exceptions where evidence supports it, and do not replace a durable rule with promises that future decisions will be careful.