Read the comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Olympic National Forest has been part of my life since I was two years old. I have camped there every year since, and it is one of my favorite places on earth. This place is why I fell in love with the natural world. It has made me who I am today. That is the ground from which I oppose the rescission of the 2001 Roadless Area Conservation Rule in Docket FS-2025-0001. The agency's own cost accounting contradicts its regulatory flexibility conclusion. "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 is reached not by examining the guides and outfitters who actually hold permits in the affected roadless areas, but by averaging a $9 million annual expenditure loss across every small firm in the sector nationally, a method the supporting analysis itself concedes may leave some firms absorbing the full loss of those receipts. Outfitters and guides operating in Olympic National Forest and forests like it are not a national average. They are specific businesses serving specific landscapes, and the rule change would reach them directly. I ask that the agency withdraw the small-entity certification and assess the impact on the businesses actually permitted and operating in the potentially affected roadless areas. Planning and recreation decisions made in reliance on the 2001 rule deserve weight here, and the agency has not given them any. "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." This comment is exactly the kind of reliance interest the solicitation invites. People who have built their relationship to these forests, their sense of where wild land would remain wild, around the protections the 2001 rule established are now asked to speak while the analysis treats their interests as weightless. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds further. The agency's fire data argues against its own proposal, and the effects analysis does not resolve the contradiction. "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." I camp in Olympic National Forest because it remains intact, because its forests are healthy enough to be worth returning to year after year. Road access that multiplies ignition density by a factor this large is not a neutral tradeoff against claimed wildfire hazard reduction. The agency has not quantified what increase in human-caused fire can be expected from new road construction, nor weighed that increase against whatever hazard reduction it projects. That quantification must appear in the record before any decision is made. Finally, the agency has structured this proposal to avoid analyzing its most consequential foreseeable consequence. "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." The agency cannot simultaneously treat plan amendments as beyond scope and invite the public to comment on them. If expanded timber harvest is a foreseeable result of rescinding the rule, it is part of this action, not a separate future matter, and the agency is asking commenters to do the analytical work it has declined to do itself. The foreseeable plan-amendment scenario, including the areas where timber harvest could expand, belongs inside the environmental analysis for this proposal, not outside it. Olympic National Forest made me who I am. I oppose this rescission, and I expect each of these failures of analysis to be addressed fully in the record. Sincerely, Alison Seattle, WA 98118

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. THE CLOSEST ROADLESS AREA TO MY ZIP CODE, 98115, IS GREEN MOUNTAIN IN OLYMPIC NATIONAL FOREST, WASHINGTON, ABOUT 34 MILES AWAY. THE 10 NEAREST AREAS HOLD 141,346 ACRES. EVERY ONE OF THEM STANDS TO LOSE ITS ONLY FEDERAL PROTECTION UNDER THE CURRENT PROPOSAL. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Fragmentation is quantified and not applied I go out to watch wildlife and birds, and what I look for lives in unbroken habitat. The agency measured what fragmentation costs and then set the finding aside. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. Issue 2: Carbon is stated and dropped The standing forests where I watch wildlife are doing quiet work the whole time, holding carbon. The agency states what these lands store and then drops the analysis. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. The DEIS concludes these lands will continue to sequester and store carbon, with no analysis of harvest and roading. I ask that the agency quantify the change in carbon storage and sequestration under each alternative. Issue 4: The agency's own assessments predict harm to 327 protected species I spend my time looking for wildlife in these forests, and the rarest of it is exactly what the agency's own assessments say this action is likely to harm. The agency's 428-page draft biological assessment closes: "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule. Issue 5: Foreseeable plan amendments are placed beyond scope I want my kids to have this, and what happens after this rule is the part that reaches them. The agency admits the next step and refuses to analyze it. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). The agency is asking commenters to perform the analysis it declared out of scope. I ask that the agency analyse the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Grace Nordhoff Seattle, WA 98115

Dear USDA Forest Service Leadership,I am writing to express my strong opposition to the proposed repeal of the 2001 Roadless Area Conservation Rule in Washington State. Rescinding these protections threatens nearly two million acres of pristine, undeveloped national forest land that is vital to our environment, economy, and community well-being.As a Washington resident who frequently camps and hikes in the Olympic National Forest, I have a deep personal connection to these public lands. I know firsthand how irreplaceable these wild, roadless spaces are. Allowing logging, mining, and road construction into these pristine backcountry areas will permanently destroy the quiet, natural landscapes that I and thousands of others rely on for recreation and mental well-being.I urge you to maintain the current Roadless Rule protections for the following reasons:Ecological Integrity: Washington’s roadless areas provide critical habitats for endangered and threatened species, keeping these ecosystems whole and resilient.Watershed Protection: These undeveloped lands safeguard the clean drinking water sources for millions of Washington residents and protect vital salmon-spawning streams.Climate Resilience: Leaving these mature and old-growth forests intact ensures they can continue to capture and store carbon, serving as a natural defense against climate change.Economic Value: Outdoor recreation is a major economic driver in Washington. Keeping these areas wild supports local tourism, recreation businesses, and public health.Please reject this proposal and uphold the 2001 Roadless Rule to protect the Olympic National Forest and Washington’s other irreplaceable wild forests for current and future generations. Sincerely,Markos Sauri Federal Way, WA 98023