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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The White Mountains are sacred. I cannot think of another word for them. I do not get there as often as I would like, but roadless areas in the White Mountain National Forest are places I hold as genuinely irreplaceable. Wildlife and the natural spaces they depend on have been pushed and pushed already. They have more value left as they are than anything else that can be imagined. These lands belong to the people of this country, those of the past, present, and future. The people of the past and the people of the present have paid for these lands with their tax dollars to preserve them for nature, and for those in the future who will continue preserving them. The proposed rescission of the 2001 Roadless Area Conservation Rule works against that obligation, and I ask the agency to answer the following points in the record before proceeding. The proposal invokes wildfire and fuels management as part of its rationale. The agency's own findings directly contradict that reasoning: "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 White Mountain's 16 inventoried roadless areas total 240,669 acres and serve as headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. Opening roads into those drainages increases ignition risk by the agency's own measure. I ask that the agency explain why this proposal departs from its own prior findings, and that it reconcile the rescission with the ignition data in DEIS Table 21, which shows far higher fire density on roaded land than inside affected roadless areas. The economic justification for rescission does not hold up against the agency's own numbers. The record states 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." New Hampshire alone holds 15 inventoried roadless areas totaling 234,681 acres, and across the Eastern region, which includes New Hampshire, 286 municipal water intakes sit in watersheds containing affected roadless areas. The recreational and watershed values at stake in places like the Pemigewasset and Wild River are not marginal. I ask that the agency reconcile the proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog constitutes sound management when the agency's own analysis cannot establish a net benefit. The proposal argues that state-specific approaches can substitute for a national rule. The agency's own record notes that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency tried that state-by-state substitution before, and it failed in court. Moose, black bear, American marten, Bicknell's thrush, brook trout, Canada lynx, and the northern long-eared bat all inhabit the White Mountain roadless areas. Their habitat does not respect state lines, and neither do the watersheds these areas protect. The agency must address its own prior finding that local decision-making incrementally erodes nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time a state-by-state approach was attempted. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. That question was already answered. 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." The court found the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The Weeks Act of 1911 itself was passed specifically because of what happened when New England's mountains were clearcut. The White Mountains are what they are because of federal protection, not despite it. The agency must explain the legal basis for any position contrary to the Tenth Circuit's holding before this rescission proceeds further. Sincerely, John Minkle Malden, MA 02148

I write in opposition to rescinding the 2001 Roadless Area Conservation Rule. I grew up hiking and camping in the White Mountain National Forest and have spent weeks in the Green Mountain National Forest. I visit less often now that I am older. Yet I return to the White Mountains to be embraced by forested lands for a refreshing respite from my urban life, breathing the bracing, scented air deeply. The Roadless Rule safeguards nearly 45 million acres of national forest lands. We came to these stewardship protections the hard way, after suffering great losses whose lessons we risk forgetting. During Reconstruction after the Civil War, demand for timber was high and forest clearing widespread. In 1873, the young superintendent of the Adirondack Survey, Verplanck Colvin, age 26, could see the forest for more than the trees. He warned that continued clear-cutting would reduce water flowing to the Erie Canal and Hudson River, commercial waterways on which New York’s burgeoning economy depended. Vermonter George Perkins Marsh’s book, Man and Nature; or, Physical Geography as Modified by Human Action, helped people understand how destroying forests could undermine the watersheds sustaining their prosperity. New York established the New York State Forest Preserve in 1885, protecting approximately 681,000 acres in the Adirondacks and another 34,000 acres in the Catskills. Much of this land had come into state ownership through unpaid-tax forfeitures after logging and abandonment. Subsequent purchases and other acquisitions expanded the protected forests. New York recognized that these watersheds' public value extended far beyond the timber standing on them. The Green Mountain and White Mountain National Forests also protect headwater streams that feed rivers across state boundaries. The White Mountain National Forest contributes to the Connecticut, Merrimack, Saco, Androscoggin, and Presumpscot river systems. The Green Mountain National Forest shelters headwaters of the White, West, and Deerfield Rivers, which feed the Connecticut; the Batten Kill, renowned for trout fishing, which feeds the Hudson; and Otter Creek, which flows into Lake Champlain. Opening inventoried roadless areas to additional roads and timber harvesting would put these upstream protections at risk. The consequences could reach downstream communities through erosion, sedimentation, and damage to water quality and aquatic habitat. Decisions made within one national forest can affect people far beyond its boundaries. Rescinding the Rule would be penny-wise for logging industries and pound-foolish for Americans. I urge USDA to retain the 2001 Roadless Rule. Rob Moir, PhD Executive Director Ocean River Institute 12 Eliot Street Cambridge, MA 02138