Read the comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The wonders of Lassen National Forest deserve better than this. I hike the area around Lassen National Volcanic Park, and while I greatly value the Park itself, what I prize is the expansive forest beyond it, where I can hike with my dog and move through country that roads have not divided. That country exists because the 2001 Roadless Area Conservation Rule exists. This proposal to rescind it is wrong, and the agency's own analysis says so more plainly than I can. The strongest argument against rescission is written into the fire data the agency collected. The DEIS states this plainly: "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014–2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." That is nearly eight times the ignition rate on roaded land. The effects analysis then concedes that new road access could increase the number and frequency of wildfires. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it honestly against the claimed reduction in wildfire hazard, in a public document where the math can be examined. Punching roads into roadless areas opens these areas to excessive logging, often irresponsible motor vehicle traffic, and accelerated erosion, threatening the pristine waters that provide tap water to thousands, perhaps millions, of households. The roads themselves are sources of erosion and contamination. The agency's own data supports this directly: it has found that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of the watersheds fed by roadless areas have impaired streams today. That proportion will not hold if this rule is rescinded. The agency must explain, on the record, how it can accept that tradeoff. The regulatory flexibility analysis does not survive scrutiny either. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." That certification was reached by spreading loss across every small firm nationally rather than examining the outfitters and guides actually holding permits in the affected areas. The analysis concedes some of those firms may lose those receipts. The certification should be withdrawn and replaced with an assessment of the small entities actually operating in these areas, not a national average that dilutes the real harm. The range of alternatives considered was narrowed before analysis began. Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it “would continue to restrict local decision-making discretion” and because analysing roadless values is “an administrative and legal burden for the agency." A purpose statement written as deregulation from the start forecloses the comparison NEPA requires. I ask that the agency restate the purpose and need in terms of actual forest conditions and analyze at least one protective alternative in full. Finally, the reliance interest problem is one the agency itself opened. 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. I hike in the Lassen National Forest in part because I have understood that roadless character to be durable. That understanding is a reliance interest. The agency must identify and weigh the reliance interests that commenters describe, not invite them and then leave them unexamined in the record. Rescinding this rule sacrifices habitat, water quality, and carbon storage for what is, at best, a short-term and questionable gain. The ecosystem services these areas provide are not recoverable once roads fragment them. A logged stand grows back. The Forest Service should withdraw this proposal. Sincerely William M Loker Chico, CA 95926