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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Cache National Forest is my backyard. I hike throughout Utah, but the mountains above Cache County are where I find quiet, photograph clear mountain streams and high ridgelines with no visible sign of human impact, where wild animals still gather and thrive away from modern development and machines. Cutler Marsh in Cache County is where I paddle, fed by the Logan River and the Blacksmith Fork River, both of which have their headwaters in Cache National Forest, and by the Bear River, with headwaters in the Uinta National Forest. The water quality in that marsh begins in these roadless areas. I oppose the rescission of the 2001 Roadless Area Conservation Rule as proposed in Docket FS-2025-0001. I serve as the Cache County Trails and Active Transportation Coordinator. In that role I have seen what good local/federal partnership looks like. In the Wellsville Mountains, 1,717 acres in the Wasatch-Cache National Forest, I spent years working on a project with the county to open additional access for hikers, campers, and horseback riders through a new trailhead. Access into those mountains is not a federal problem. This should be a local-led effort and we have made big strides locally with Forest Service support and without touching the roadless character of the land. Around Clarkston Mountain, 7,099 acres in the Caribou National Forest, I have been working to preserve existing roads already in the area. With those existing roads preserved there will be plenty of access and recreation opportunities with no need to impact or change the existing roadless portions. The Mt. Logan roadless area is different in what would be lost. I have been hiking in and around Mt. Logan South (17,014 acres), Mt. Logan North (18,930 acres), and Mt. Logan West (5,285 acres), all in the Wasatch-Cache National Forest, for almost 8 years. I have spent many Saturdays maintaining trails and helping people with disabilities get out and enjoy them. I have seen all kinds of wildlife who still call this yet unfragmented place home. To the south of this area there is already land crisscrossed with roads, and hiking there is a very different experience, with less diversity in the animals you are likely to see and the constant noise of machines. It makes sense to allow different areas to serve different recreation and access needs rather than making the whole of our wild lands look and feel the same. The agency's own record makes this concern concrete. Its draft environmental impact statement states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless justifies rescission partly on wildfire and fuels management grounds. I ask that the agency reconcile this contradiction: explain specifically why the proposal departs from its own prior findings on fire occurrence, and reconcile the rescission with the ignition data in its own DEIS, which reports higher fire density on roaded land than inside the affected roadless areas. The proposal overstates what the rule prohibits. The agency's own text notes that the rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If the justification for rescission is permitting burden and administrative difficulty, I ask that the agency identify which burdens are not already addressed by those existing exceptions and quantify those burdens with specificity on the record. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres. Across the Intermountain region, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The proposed rescission's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year, yet the regulatory flexibility analysis certifies no significant impact on small entities by averaging that loss across every small firm in the sector nationally rather than examining the outfitters, guides, and tour operators actually holding permits in these areas. I ask that the agency withdraw that certification and assess impacts on the specific small entities operating in potentially affected roadless areas. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My work coordinating trails and access in Cache County, the public investment in the Wellsville trailhead, and the years of volunteer trail maintenance in the Mt. Logan roadless areas rested on the assumption this rule would hold. Sincerely, Landis Wenger Logan, Utah

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Most of my life has been spent living near the Wellsville Mountains. I have hiked and camped there, and my daughters camped with the Girl Scouts in the Wellsvilles. I ride trails in the Cache National Forest, paddle the lakes where I camp, and photograph wildlife, landscapes, and the night sky across the Cache National Forest and throughout the southwest desert. The Wellsville area covers 1,717 acres in the Wasatch-Cache National Forest. Mt. Logan West, at 5,285 acres, sits right next to where I live. Mt. Logan South, 17,014 acres, is where I hike and camp. Willard, at 18,059 acres, gives a great view of the Salt Lake Valley. Mt. Logan North covers 18,930 acres, and Clarkston Mountain, 7,099 acres in the Caribou National Forest, is another wild place near where I live, and I want to keep it that way. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The agency has argued that rescission is partly justified by wildfire and fuels management concerns, but the agency's own record contradicts that rationale directly. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I hike, camp, and ride trails in the Cache National Forest, and the areas I named sit within it. The ignition data in DEIS Table 21 shows far higher fire density on roaded land than inside the affected roadless areas. The agency must explain, plainly and in the administrative record, why this proposal departs from those findings. The economic case for rescission fares no better than the wildfire rationale. The agency's own record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, set against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. Utah alone holds 222 inventoried roadless areas totaling 4,013,529 acres. How does the agency justify expanding a road system already carrying a $6.9 billion maintenance backlog when its own analysis cannot establish a net benefit? The proposal argues that state-specific approaches can substitute for a single national rule. When the agency previously took that position and replaced the 2001 rule with a state-by-state framework, that effort was rejected in litigation on grounds that local decision-making can incrementally erode nationally significant roadless values. The agency has not explained how this rescission avoids those same deficiencies. I want to keep the wild places near where I live wild, and I ask the agency to address in the record how a return to piecemeal management protects nationally significant roadless values that no single state-level process can fully secure. Finally, the agency has suggested that the 2001 rule exceeded its statutory authority. The courts that examined that precise question disagreed. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court further held that the 2001 rule fell within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must state clearly in the record the legal basis for any position contrary to that holding before proceeding further with this rescission. Sincerely, Karl Pettigrew Logan, Utah