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Brief summary of my letter, attached: I am submitting these formal comments to express my unequivocal opposition to the Department of Agriculture and Forest Service’s proposed rescission of the 2001 Roadless Area Conservation Rule (Docket No. FS-2025-0001; 90 Fed. Reg. 42179). I write as an applied natural resource economist with nearly 40 years of academic research and field experience examining the complex relationships between public land policy, natural ecosystem functioning, and regional economic development. As a resident of Virginia's Shenandoah Valley—situated directly between the George Washington and Jefferson National Forests—and as the author of several empirical research reports on the economics of public lands conservation (e.g., Virginia's National Forests and the Virginia Economy, 2002; Windfalls for Wilderness: Land Protection and Land Value in the Green Mountains, 2000; et al.) I have studied firsthand how forest conservation drives sustainable prosperity across rural communities in the Appalachians and across the United States. From an applied economic and public policy perspective, the Forest Service’s proposal to dismantle nationwide protections across 44.7 million acres of Inventoried Roadless Areas (IRAs) is economically inefficient, fiscally irresponsible, and analytically unsupportable. The agency’s justification rests on two demonstrably false premises: first, that opening IRAs to road construction and commercial logging is necessary to expand domestic timber supply and stimulate rural economies; and second, that road building is required to reduce catastrophic wildfire risk. As demonstrated by the Forest Service’s own official Cost-Benefit Analysis (USDA Forest Service, 2025b) and 33-year empirical fire datasets (Aplet et al., 2025), repealing the Roadless Rule will: - Yield a negligible, less-than-trivial contribution to national and state timber supplies while incurring high, below-cost extraction expenditures; -Severely exacerbate an existing $7 billion to $10 billion road deferred maintenance backlog for an agency that currently receives less than 20% of necessary annual road upkeep funding; - Liquidate billions of dollars in high-value ecosystem services, including clean drinking water filtration, flood mitigation, carbon sequestration, and municipal watershed protection; - Degrade the natural amenity assets that drive modern rural population growth, high-wage employment, and private property value enhancement; and - Directly increase wildfire ignition risks by extending road access—the primary vector for human-caused ignitions—into currently intact, low-ignition forest interiors. Furthermore, the agency’s rulemaking notice violates the National Environmental Policy Act (NEPA) and Executive Order 12866 by failing to evaluate "cumulative impacts" and "reasonably foreseeable" site-specific harms, while presenting a Cost-Benefit Analysis that reveals a negative Net Present Value (NPV) of up to -$92 million (USDA Forest Service, 2025b). I therefore urge the Department to withdraw this flawed rulemaking immediately. Rescinding the 2001 Roadless Area Conservation Rule represents an unjustified economic and fiscal misstep. It liquidates high-value, self-sustaining natural capital—clean water, carbon storage, backcountry recreation, and amenity-driven regional growth—to deliver a fractional, below-cost timber volume while expanding a road network that the Forest Service cannot afford to maintain and that directly increases wildfire risk. I formally request that the Department of Agriculture and the Forest Service: + Immediately withdraw Docket No. FS-2025-0001 and maintain the 2001 Roadless Area Conservation Rule in its entirety; + If the agency proceeds, prepare a comprehensive Regulatory Impact Analysis (RIA) under Executive Orders 12866 and 13563 that fully quantifies non-market ecosystem service losses, passive use values, and long-term road maintenance liabilities; and + Remedy the fundamental legal and analytical deficiencies in the Draft Environmental Impact Statement (DEIS) by conducting a thorough, site-specific "hard look" at cumulative environmental impacts, wildlife habitat fragmentation, and watershed degradation across individual Inventoried Roadless Areas, rather than unlawfully deferring site-specific analysis to future project-level decisions. -Spencer Phillips, PhD, Staunton, Virginia

Brief summary of my letter, attached: I am submitting these formal comments to express my unequivocal opposition to the Department of Agriculture and Forest Service’s proposed rescission of the 2001 Roadless Area Conservation Rule (Docket No. FS-2025-0001; 90 Fed. Reg. 42179). I write as an applied natural resource economist with nearly 40 years of academic research and field experience examining the complex relationships between public land policy, natural ecosystem functioning, and regional economic development. As a resident of Virginia's Shenandoah Valley—situated directly between the George Washington and Jefferson National Forests—and as the author of several empirical research reports on the economics of public lands conservation (e.g., Virginia's National Forests and the Virginia Economy, 2002; Windfalls for Wilderness: Land Protection and Land Value in the Green Mountains, 2000; et al.) I have studied firsthand how forest conservation drives sustainable prosperity across rural communities in the Appalachians and across the United States. From an applied economic and public policy perspective, the Forest Service’s proposal to dismantle nationwide protections across 44.7 million acres of Inventoried Roadless Areas (IRAs) is economically inefficient, fiscally irresponsible, and analytically unsupportable. The agency’s justification rests on two demonstrably false premises: first, that opening IRAs to road construction and commercial logging is necessary to expand domestic timber supply and stimulate rural economies; and second, that road building is required to reduce catastrophic wildfire risk. As demonstrated by the Forest Service’s own official Cost-Benefit Analysis (USDA Forest Service, 2025b) and 33-year empirical fire datasets (Aplet et al., 2025), repealing the Roadless Rule will: - Yield a negligible, less-than-trivial contribution to national and state timber supplies while incurring high, below-cost extraction expenditures; -Severely exacerbate an existing $7 billion to $10 billion road deferred maintenance backlog for an agency that currently receives less than 20% of necessary annual road upkeep funding; - Liquidate billions of dollars in high-value ecosystem services, including clean drinking water filtration, flood mitigation, carbon sequestration, and municipal watershed protection; - Degrade the natural amenity assets that drive modern rural population growth, high-wage employment, and private property value enhancement; and - Directly increase wildfire ignition risks by extending road access—the primary vector for human-caused ignitions—into currently intact, low-ignition forest interiors. Furthermore, the agency’s rulemaking notice violates the National Environmental Policy Act (NEPA) and Executive Order 12866 by failing to evaluate "cumulative impacts" and "reasonably foreseeable" site-specific harms, while presenting a Cost-Benefit Analysis that reveals a negative Net Present Value (NPV) of up to -$92 million (USDA Forest Service, 2025b). I therefore urge the Department to withdraw this flawed rulemaking immediately. Rescinding the 2001 Roadless Area Conservation Rule represents an unjustified economic and fiscal misstep. It liquidates high-value, self-sustaining natural capital—clean water, carbon storage, backcountry recreation, and amenity-driven regional growth—to deliver a fractional, below-cost timber volume while expanding a road network that the Forest Service cannot afford to maintain and that directly increases wildfire risk. I formally request that the Department of Agriculture and the Forest Service: + Immediately withdraw Docket No. FS-2025-0001 and maintain the 2001 Roadless Area Conservation Rule in its entirety; + If the agency proceeds, prepare a comprehensive Regulatory Impact Analysis (RIA) under Executive Orders 12866 and 13563 that fully quantifies non-market ecosystem service losses, passive use values, and long-term road maintenance liabilities; and + Remedy the fundamental legal and analytical deficiencies in the Draft Environmental Impact Statement (DEIS) by conducting a thorough, site-specific "hard look" at cumulative environmental impacts, wildlife habitat fragmentation, and watershed degradation across individual Inventoried Roadless Areas, rather than unlawfully deferring site-specific analysis to future project-level decisions. -Spencer Phillips, PhD, Staunton, Virginia See attached file(s)

Comment on Proposed Rule: Special Areas; Roadless Area Conservation RIN 0596-AD66 | Docket FS-2025-0001 | 91 FR 53827 I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and ask the Department to withdraw it. My full comment is attached. The Department already knows what the public thinks. Its own preamble reports that the 2025 notice of intent drew more than 220,000 comment letters on behalf of over 625,000 individuals and organizations in twenty-one days, and that "the majority sentiment among Tribal governments consulted is opposition." Independent analysis found opposition above 99 percent of unique submitters. A December 2025 national poll by Susquehanna Polling and Research for The Pew Charitable Trusts found likely voters support the Roadless Rule 76 to 13 percent, with support highest among Republicans at 77 percent; 87 percent said national forest areas should be kept mostly undeveloped and intact, against 7 percent favoring more timber production and roads. The rule being rescinded was adopted on the largest public record in this agency's history: 600-plus hearings and over 1.6 million comments. I ask the final rule to state plainly what public support the Department believes exists for this action, and to identify the evidence for it. Notice-and-comment is not a referendum, and I do not ask the Department to treat it as one. But this record is evidence the APA requires the Department to engage: of the reliance interests it must weigh in reversing a settled policy, of the public values MUSYA and NFMA require it to consider, and of the 2001 factual findings it must confront before abandoning them. The attached comment sets out 49 reasons. The principal ones: Rescission is unnecessary. The preamble itself notes that any State or Tribe may petition for tailored roadless provisions under 5 U.S.C. 553(e) and 7 CFR 1.28. Idaho and Colorado did exactly that, and this proposal preserves both state rules. Local flexibility does not require eliminating the national baseline. The legal questions are settled. The rule was challenged in the Ninth, Tenth, and D.C. Circuits and prevailed in each; the Supreme Court denied certiorari in 2012. No challenge to the 2001 Rule has ever succeeded on final judgment. The suits that did succeed struck down attempts to weaken it, including Organized Village of Kake v. USDA, 795 F.3d 956 (9th Cir. 2015) (en banc), which held the 2003 Tongass exemption arbitrary and capricious precisely because the Department reversed its own 2001 findings without explanation. That is the defect in this proposal, on a national scale. The preamble cites that litigation history as a reason to rescind; it shows the opposite. The economics do not work. The Department projects $5.2-11.4 million per year to the Treasury from timber, against roughly $6.1 million in annual recreation losses and a conceded $6.9 billion deferred maintenance backlog for roads and bridges. It calls the rule economically significant under E.O. 12866 and says impacts "could exceed $100 million," yet certifies no significant impact on small entities under the Regulatory Flexibility Act. Those findings need reconciling. The wildfire rationale is self-contradicting. The preamble concedes "greater public access can increase human-caused ignition potential." Only 24 percent of inventoried roadless acres overlap the wildland-urban interface, so a nationwide rescission is far broader than the stated community-protection purpose requires. The current rule already allows fire and fuels work. The NEPA analysis is segmented. The Department concedes that subsequent plan amendments "could increase the area where timber harvest and road construction would be allowed," then declares those effects beyond scope while soliciting comment on them. It also declines to fully analyze the No Action, Strengthened Roadless Rule, and Traditional Homelands alternatives commenters requested. Tribal consultation is unfinished. Of 64 requests, 34 were scheduled and 29 held. The final Tribal Impact Summary Statement is to issue with the final rule, after comment closes, so neither Tribes nor the public can comment on it. The ANILCA 810 subsistence analysis is likewise outside this period. I ask the Department to withdraw the rule; failing that, to select No Action, fully analyze the requested alternatives and foreseeable plan amendments, publish the Tribal and subsistence analyses for comment before any final rule, reconcile its economic findings, confront its 2001 findings and the reliance built on them, and use the existing petition process for documented local needs. I have hiked the entirety of the Pacific Crest Trail and the Tahoe Rim Trail and explored National Forests in more than twenty states. Much of that ground was inventoried roadless area. These places are drinking water, habitat, and the last unfragmented country we have, and there is no process that makes more of them.

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 have climbed 140 peaks over 5000 feet in Southern California, over 25 in the Sierra Nevada, and about a dozen in the California Desert. This has created both a lot of enjoyment and a lot of economic activity. Roadless areas include 43,000 miles of trails, 11,000 climbing routes, and 1,000 whitewater rafting runs that bring visitors and billions of dollars to small towns across America. That stops if these roadless areas are logged or mined. The economic benefits of the areas protected by the 2001 Roadless Rule far outweigh the benefits of rescission of this rule. In Southern California, most of our water supply originates in these Roadless Areas or adjacent Wilderness areas. This high quality water is essential to the success of businesses in Southern California. Opening these Roadless Areas to roadbuilding or mineral development threatens this clean water. As a taxpayer, I resent that the Forest Service processes and approves logging that costs me money. In the 2018 fiscal year, the USFS spent $388 million on its Forest Products program and only collected $41 million in receipts. This is an outrageous waste of taxpayer money, when the undeveloped forest has so many beneficial uses. The Tongass Forest logging program cost US taxpayers $1.73 billion between 1980 and 2019!! Executive Order 12866 requires an accounting of NET benefits, not gross receipts. Why has this not been done?? Roadless lands generate a net benefit estimated to be $24 billion a year, a permanent annual dividend from these undeveloped roadless lands. Trading that for a one-time logging or mineral development is not worth the loss of these roadless lands. Local decision-making often results in loss of national values. A local Forest Service Supervisor might please local residents when roadless areas are developed. But national values of those lands would be lost. Tourism would suffer, when people no longer visit former roadless areas that have been spoiled. Why would the Forest Service want to build ANY roads, when there is a $6.0 billion maintenance backlog on the roads that already exist??? Fix what has already been built, before you build more roads that the taxpayer can not afford to maintain!! The FS spends a huge amount of money on fire fighting. Roads are ignition corridors! 89% of wildfires nationally are human-caused. I was nearly trapped by the Caldor Fire in the Sierra Nevada in 2021. A home on my cul de sac was burned to the ground by the 2008 Freeway Complex Fire. Both of these were human-caused. The 2001 Roadless Rule DOES allow fuel treatments, as shown by over 2 million acres or roadless lands being treated. The fuels treatment is limited by appropriations and workforce capacity, not the fact that these lands are roadless. Stop the insanity! Do NOT rescind the 2001 Roadless Rule!!

To the U.S. Forest Service: I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user and advocate for our nation's public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. I frequently visit Sam’s Knob near my home in Asheville, NC. Protecting these unfragmented landscapes is deeply personal to me because I hike the backcountry trails and I value the pristine wildlife habitat. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Thank you for the opportunity to provide public comment. Sincerely, Esther Hales Omission of Invasive-Species Establishment and Treatment Cost from the Quantified Cost Column of Cost Benefit Analysis Table 1 The Comparison of Alternatives table states that “Forest Service data indicates less than one percent of the affected environment has mapped invasive plant populations,” and that where activities increase under alternatives 2 and 3, “they could potentially increase the extent or the number of invasive plant species, especially if they create ground disturbance” (DEIS p. 32). The invasive plant species effects discussion repeats that conclusion (DEIS p. 116) and adds the agency’s own cost finding for alternative 2: “there would also likely be an increased cost associated with detecting and treating new invasive plant populations.” Neither passage projects an acreage, a spread rate, or a dollar figure for any alternative. The only acreage given is the existing 270,787 acres of invasive plants within the alternative 3 affected area, which is a baseline, not an effect. This is not a general objection to qualitative analysis. Table 1 of the Cost Benefit Analysis (p. 5) monetizes the benefit side of this rule at $9.9 to $22.0 million per year in timber benefit to society, and it monetizes two cost categories: lost recreation benefits at -$6.1 million and forgone passive use values at -$5.3 to -$11.5 million. Invasive-species establishment and treatment appears nowhere in that table, although the Cost Benefit Analysis states at p. 27 that road construction “contributes to soil erosion, sedimentation, risk of invasive species and habitat fragmentation,” and although the DEIS states that detection and treatment costs would likely rise. The agency has identified the effect, identified the cost, and then left it out of the only table in which costs are quantified. The stated reason for qualitative treatment does not reach this category. The Cost Benefit Analysis explains that “the rulemaking would not compel, require, or authorize any site-specific activities” and that “it is difficult to predict quantitative changes in costs or benefits” (p. 20). But lost recreation benefits and forgone passive use values are equally non-site-specific, and the agency monetized both across the same acreage on the same programmatic assumptions. Whatever method supported those two lines is available for this one. If it is not, the analysis should state why this category alone is different. Deferral to project-level analysis does not answer this either. The rescission itself fixes the acreage in which the prohibitions on road construction, reconstruction, and timber harvest no longer apply; the exposure follows from that rule-level determination, not from any later project decision. In Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), a programmatic EIS was held inadequate for deferring analysis of the spread of Port-Orford-cedar root disease to the site-specific stage where the programmatic decision governed the exposure. The invasive plant species discussion here rests on “future project design features and management requirements to mitigate invasives species introduction and spread” (DEIS p. 116) without disclosing what those measures are, what they cost, or what residual spread they leave after mitigation. The quantification direction is one the agency invoked itself. The Cost Benefit Analysis records at p. 4 that this rule was determined significant for purposes of Executive Order 12866 and requires OMB review, and that Executive Order 13563 “emphasizes the importance of quantifying both costs and benefits, reducing costs, maximizing net benefits.” A regulatory analysis prepared under those orders that monetizes the benefit side and two selected cost categories, while omitting a cost the agency’s own effects analysis says will rise, gives no reasoned basis for the omission and does not permit a reasoned comparison of alternatives.

This proposed rule fails to fully account for the economic impacts as required by EO 12866. This deficiency is material and the proposed rule should be abandoned as is. Any economic analysis must take into consideration the economic benefits associated with health wilderness and forest lands. Roadless wilderness scientifically proven to be healthier, maintaining higher ecological integrity, purer watersheds, and greater biodiversity than roaded or developed landscapes. These are massive economic benefits from the current status quo that are not accounted for in this proposed rule. If the proposed rule is enacted, the economic cost to communities, states, and the nation would run in the billions of dollars, while the new economic benefits would only be in the millions of dollars. This failure to consider the economic impacts also results in this proposed rule being in violation of the Administrative Procedures Act. Adopting the proposed rule as is would result in the rule being "arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law" under 5 U.S.C. § 706(2)(A) for its failure to properly address critical evidence presented in the record.

Tyler Batdorf, 2221 SW 1st Ave Apt 924, Portland, OR 97201 August 20, 2026 Re: Comment in Opposition to Proposed Rescission of the 2001 Roadless Area Conservation Rule (36 CFR Part 294, Subpart B) — Docket FS-2025-0001, RIN 0596-AD66 I oppose this proposed rescission. I am a backcountry recreationist who uses inventoried roadless areas (IRAs) in Oregon and the Pacific Northwest, and I have reviewed the proposed rule and its "Summary of Potential Impacts." My comment focuses on places where the Department's own disclosures in this rule undercut its stated rationale. **1. The wildfire rationale ignores the Forest Service's own research.** The "Rationale for the Proposal" cites wildfire risk as a reason for rescission. But the Forest Service's own Research and Development program has found that fuel-treatment activity has actually occurred at a higher per-acre rate in roadless areas than in roaded areas, and that roaded and roadless forests have burned at similar rates since 2001, a "neutrality" its researchers attribute to higher human-caused ignition near roads offsetting suppression-access gains. Recent peer-reviewed work using 30 years of national-forest fire records found ignition density roughly three times higher within 250 meters of a road than beyond 2,000 meters, and concluded new roads into roadless terrain are likely to increase total ignitions. The proposed rule does not address this research anywhere in its "Wildfire risk" discussion. I request the Department directly address its own R&D findings before finalizing this rule. **2. The Department's own cost-benefit figures don't support the rule.** The "Summary of Potential Impacts" states rescission would open only 4.8 million acres (16%) of forested IRAs to new active management, generating just $5.2–11.4 million/year in public revenue, against a disclosed $6.9 billion road maintenance backlog, $6.1 million/year in lost recreation value, and a total annual cost the Department itself says "could exceed $100 million." I request a single reconciled accounting showing how the claimed benefits outweigh these disclosed costs, particularly given this rule's designation as "economically significant" under E.O. 12866. **3. Case-by-case NEPA review may not reduce burden.** The rule states future projects would still require site-specific NEPA compliance at the individual forest level. Replacing one national standard with review at 175+ forest units is not self-evidently less burdensome, and the rule does not compare the administrative cost of each approach. **4. Litigation history should factor into the durability analysis.** The rule's own "Background" section describes the 2001 Rule as having been enjoined and reinstated multiple times, including a Ninth Circuit affirmance in *California ex rel. Lockyer*. Combined with the majority Tribal opposition and consultation concerns documented in this same docket, a rushed rescission is likely to face comparable challenge, undermining the near-term benefits claimed. **5. Thirty days is inadequate for an economically significant rule.** This comment period is shorter than the 21-day NOI period that 54 members of Congress already called insufficient, despite covering a full proposed rule, draft EIS, and cost-benefit analysis spanning ~45 million acres. I request an extension to at least 60 days. **Conclusion:** The Department's own disclosures — not outside assumptions — show disclosed costs exceeding disclosed benefits, an unaddressed body of agency fire research cutting against the wildfire rationale, and unresolved litigation risk. I urge the Department to retain the "No Action" alternative and withdraw this proposed rescission of 36 CFR Part 294, Subpart B, or at minimum to extend the comment period and reconcile these figures before proceeding to a final rule. Sincerely, Tyler Batdorf

I am opposed to rescinding the roadless rule for the following reasons. Fire danger: Intact forests that have not been logged have uneven-aged stands, larger trees farther apart, and more moisture-absorbing ground cover. They are not as prone to dangerous crown fires as logged areas that have grown up as even-aged stands and are choked with small trees and brush. Roads bring people, vehicles and activity, which bring sources of ignition. When you talk about forest management for fire prevention, you may be hoping that we imagine brush clearing or managed burns. But in fact, what usually happens is that areas are clearcut, leaving even-aged stands to grow up and be more fire-prone. You quote President Trump as saying, “the United States has an abundance of timber resources that are more than adequate to meet our domestic timber production needs, but heavy-handed Federal policies have prevented full utilization of these resources.” Timber production is not the same as “targeted fuels treatments.” In fact, it can be the opposite. Many areas, especially in the west, have fire-adapted ecosystems that naturally burn and re-grow when ignited by lightning, for example. In a roadless area that is far from human settlement, fires can be allowed to take their course. Once there are mines, oil wells and lumber camps, there will be more infrastructure and people to protect and a greater need for fire suppression. Ecosystem Services: To some people, an intact forest produces nothing unless it is logged or mined. But in fact, it produces services of great value: clean water, clean air, fish and wildlife, natural beauty, soil formation, erosion prevention. Development: Even though you say that rescinding the rule only provides flexibility and doesn’t actually require road building, logging or mining, it’s obvious that exploitation is the goal. You mention the income that could be produced for timber companies and the federal government if logging is allowed. But it’s well known that the government subsidizes logging on federal land, so it would be a money loser for the taxpayer. Predictability: “EO. 13563 reaffirms the principles of E.O.12866 while calling for improvements in the Nation’s regulatory system to promote predictability, to reduce uncertainty, and to use the best, most innovative, and least burdensome tools for achieving regulatory ends.“ The best way to promote predictability is not to change the rule! Uncertainty will be magnified when each forest service unit creates its own plans. I feel like I’ve spent my whole adult life trying to keep roadless areas from being opened up. When is this going to stop? Just leave them alone.

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.