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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I recently was lucky enough to spend some time in Tongass National Forest. We spent 2 hours in total and I feel like I could have spent days. The towering old growth trees were magical. Not a road in site. I felt at peace here. I grew up in Superior Wisconsin and my family would take trips to BWCA and Superior National Forest in the summer. The only transportation was boats, usually just canoes. Again, no roads. It is magical. Losing this would mean losing a place where kids learn about the power of nature. My family used to spend some summers in Big Sky, near the Custer Gallatin NF. We would venture off and hike the trails with our bear spray. Words don't do it justice how amazing this land is without any roads. It is just you, nature, and the animals. My comment concerns the following inventoried roadless areas specifically: - Tongass National Forest (9,339,575 acres), Tongass National Forest, Alaska - Superior National Forest (62,000 acres), Superior National Forest, Minnesota - Custer Gallatin NF (848,000 acres), Custer Gallatin NF, Montana Together these areas hold 10,249,575 acres of inventoried roadless land. I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Wildfire and fuels management The proposal justifies rescission in part on wildfire and fuels management grounds. The agency’s own record 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." (Roadless Area Conservation FEIS Vol. 1 (Nov. 2000), fire-occurrence discussion, printed p. 3-115) "The net result is that there is a substantially increased level of fire occurrence outside inventoried roadless areas." (Roadless Area Conservation FEIS Vol. 1 (Nov. 2000), text introducing Table 3-19 (human-caused fire occurrence 1986-1996), printed pp. 3-104 to 3-105) I ask that the agency explain in the DEIS why it now departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it disclose and analyze the increased risk of human-caused ignition that its own 2000 FEIS associated with road construction. Issue 2: Timber economics and jobs The proposal justifies rescission in part on timber economics and employment grounds. The record before the agency states: "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." (66 FR 3244, national social and economic effects discussion (citing FEIS Vol. 1, 3-326 to 3-350)) "there presently exists a backlog of about $8.4 billion in deferred maintenance and reconstruction on the more than 386,000 miles of roads in the Forest Transportation System." (66 FR 3244, "Fiscal Considerations", printed pp. 3245-3246) I ask that the agency reconcile the proposal with its own prior economic findings, including the scale of the timber production actually affected and the deferred maintenance backlog on the existing road system, and that it disclose the fiscal consequences of expanding that system. I ask that the agency address the Tenth Circuit’s holding that the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness, and that it explain in the DEIS the basis for any contrary position. 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 for the areas named above. 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, Will Rogers Elmhurst, IL 60126