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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The birds and the terrain keep pulling me back. I backpack, fish, and take in the scenery in the Ozark National Forest, and I also backpack in the Sequoia and Inyo National Forests. I ride the Syllamore Mountain Bike Trail in the Ozark and the Ouachita Trail in the Ouachita National Forest. I paddle the Buffalo River, the White River, and Syllamore Creek. Wherever I go, I am looking for birds, especially woodpeckers and songbirds, and for deer and other mammals. Every one of those pursuits depends on forests that remain unroaded, and the agency's own record explains why opening them to roads would damage what I go there to find. I oppose this rescission. The wildlife case against this proposal is written in the agency's own science. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The woodpeckers and songbirds I seek in the Ozark are exactly the interior-forest species this research describes. I want the agency to explain, by direct reference to those cited studies, how it concludes that expanding the road system inside currently protected areas will not degrade the bird communities its own DEIS describes as road-sensitive. On deer, the agency's own record is equally plain: the DEIS cites Wyoming research finding that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed, and the agency's Tribal Summary Impact Statement credits the rule's protection with the recovery of deer populations by preserving old-growth winter shelter. Those findings come from the agency, not from opponents. The agency should explain how it reconciles the rescission with its own documentation of what unroaded security provides to deer populations. The wildfire justification the proposal offers collapses against the agency's own ignition data. 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." That is the agency's language, in its own draft environmental impact statement, and it directly contradicts using fire management as a rationale for road construction in currently protected areas. I ask the agency to explain why this proposal departs from its own prior findings on fire occurrence and to reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic arithmetic the agency offers does not hold up either. The agency's own record 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." Against those figures, the agency's own Cost Benefit Analysis 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 negative $92 million to positive $199 million, all while the road system already carries a $6.9 billion maintenance backlog. An analysis that cannot establish a net benefit is not a justification. The agency must reconcile those numbers before it acts. The legal ground under this proposal is also shaky in ways the agency has not confronted honestly. When the agency last abandoned the national rule for a state-by-state approach, it described its own 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 Ninth Circuit found that approach legally deficient. The agency needs to explain how this proposal avoids those same deficiencies and address its own prior finding that local decision-making can incrementally erode nationally significant roadless values. On the question of statutory authority, the Tenth Circuit has already spoken: "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 held the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The agency has not explained on the record the basis for any contrary position, and it should be required to do so before this proceeding advances further. Sincerely, Dennis Powers Heber Springs, AR 72543