Read the comments.

The Forest Service should keep the Roadless Rule intact exactly as it is, utilizing Alternative 1 in the current DEIS. I am deeply concerned about the proposal to rescind the Roadless Rule. Once we destroy natural landscapes, we can not get them back. Backpacking, hiking, skiing, etc will be lost for generations. Roadless areas provide important benefits to communities across the country, including clean drinking water, wildlife habitat, opportunities for outdoor recreation, and protection from the impacts of development. These lands are also an important part of the character and identity of many communities and provide places for people to hike, hunt, fish, camp, ski and otherwise enjoy the outdoors. I am particularly concerned that rescinding the Roadless Rule could increase development, reduce recreation opportunities, affect wildlife habitat, increase wildfire risk, or harm local economies that depend on outdoor recreation. The wildfire risk is already huge and growing. Let’s leave this rule intact and be good stewards to the land. The Roadless Rule has provided consistent, nationwide protections for these special places for decades. The Forest Service should not weaken those protections or open currently protected roadless lands to new development. I urge the Forest Service to pursue Alternative 1 and retain the existing Roadless Rule protections. We must protect our public lands. They are meant for all of us. Sincerely, Marjorie Allison 608 N Randolph St Macomb, IL 61455-1563 dmbmca@gmail.com

Dear Secretary Rollins, As a citizen of this country, I strongly believe in the Roadless Rule. It is a means of protection for wildlife and the environment in a time where we are seeing increasing concerns for the conservation and protections of these spaces. This isn’t a democrat vs republican issue. In a recent poll by Susquehanna Polling and Research, Inc. (https://www.pew.org/-/media/assets/2026/02/national-poll-on-roadless-rule.pdf), it showed incredible bipartisan support for the conservation and protection of national forests and roadless lands. Campers, hikers, hunters, conservationists, and more all across the political divide all agree. None of this is possible without the safeguarding of these last wild areas. If we are making the claim that these lands are a fire hazard, the Roadless Rule already allows for management projects to reduce wildfire risks (prescribed fire, tree thinning, etc). There is also research that strongly suggests that most wildfires are caused by humans, with 95% of those wildfires being within a ½ mile from a road and that only 3% of wildfires start in wilderness areas more than 1.24 miles from a road (https://www.pacificbio.org/publications/wildfire_studies/Roads_And_Wildfires_2007.pdf). Creating roads where more people can cause these issues is an issue in itself. I love our country’s forests, national parks, and wild space. I love being on public lands and seeing the beautiful areas around me. I believe that we are one of the best places in the world to view an amazing, vast expanse of wilderness and diverse ecosystems. Tourism alone to national parks, public lands, and forests draws millions of visitors and immense economic contributions to the surrounding areas and the rest of the country. In 2023-24 data alone, the National Forest Service generated over $45 billion in GDP and supported almost 400,000 jobs (https://www.govinfo.gov/content/pkg/GOVPUB-A13-PURL-gpo239285/pdf/GOVPUB-A13-PURL-gpo239285.pdf). Why would we do anything that could actively harm this? What would logging or mining or building roads in these areas do except create short-term profits that would ruin the surrounding wilderness and negatively impact the forests and wildlife would that would sustain this tourism and its economic/environmental impact over decades? This is protected land that should be protected throughout the whole country, at all times. There should be set standards that follow scientific research and safeguards that protect these spaces from officials with loyalties that undermine conservation efforts. There are already threats to the endangered animals in this country because of changing rules that prioritize fast development and corporate interests over sustainable environmental impacts. Many of these endangered species live in these roadless areas. The destruction of their habitat will create extinctions of many of these species and make our country lesser. The government is supposed to work in the interests of the people and the country as a whole. No majority in this country wants the Roadless Rule revoked. We want wild space. We want wildlife. We want clean, natural recreation space. We want our national forests, public lands, and national parks to remain for the people of this country and our future children for generations to come. Sincerely, Jennifer DeGrauwe Chicago, IL 60617 jedegra@gmail.com

I oppose the rollback of the Roadless Area Conservation Rule. For more than two decades, this rule has protected much of the wildness that remains in our national forests. The protections have been particularly vital in the Midwest, where less than 200,000 acres of roadless, untrammeled forest lands survived the widespread logging of the past two centuries. From Wisconsin's Chequamegon-Nicolet to Michigan's Ottawa, Hiawatha, and Huron-Manistee, the Midwest’s national forests have important roadless areas that provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. These roadless areas are an enormous resource In the Midwest. I urge you to stop rolling back protections for our public lands and leave our last wild forests intact. Please keep the Roadless Rule in place. Sincerely, na A McKinzie 42 BERKSHIRE St Oak Park, IL 60302 alison.mckinzie@gmail.com (773) 793-6292

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Public lands belong to everyone, and they should be managed for recreation and the enjoyment of nature. Biodiversity is our lifeline, and the importance of nature needs to be preserved for upcoming generations. The proposal to rescind the 2001 Roadless Area Conservation Rule does neither of those things, and the agency's own record does not support it. The agency justifies rescission partly on wildfire and fuels management grounds, but its own findings cut against that position. The 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." The agency must explain why this proposal departs from those prior findings and how it reconciles the rescission with the ignition data in its own draft environmental impact statement, which the record indicates shows far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is equally weak on the agency's own terms. The 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." 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, with a net present value spanning -$92 million to +$199 million. That range does not establish a net benefit. The agency should explain on the record how opening a road system already carrying a $6.9 billion maintenance backlog is justified when its own numbers cannot confirm the proposal pays for itself. The agency argues that state-specific approaches can replace a single national rule, but that argument has a history. The record shows that the agency previously expressed "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." That prior attempt to substitute local decision-making for a national standard was reviewed in court and found wanting. The agency has not addressed its own earlier finding that local decision-making can incrementally reduce nationally significant roadless values, and it has not explained how this proposal avoids the same deficiencies the Ninth Circuit identified when the agency last tried a state-by-state approach. That question deserves a direct answer. On statutory authority, the agency argues the 2001 rule exceeded what Congress granted. The Tenth Circuit addressed exactly that question and 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 agency needs to address that court's holding that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and it needs to state plainly what legal basis supports a contrary position now. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. These are the last unroaded third of the national forests, and a road, unlike a logged stand, does not grow back. The agency should answer each of the points raised here before it proceeds further. Sincerely, Nilisha Patel Chicago, IL 60607

The Roadless Area Conservation Rule must not be rolled back. This rule protects the wildness of our national forests. The protections have been particularly vital in the Midwest, where less than 200,000 acres of roadless, untrammeled forest lands survived the widespread logging of the past two centuries. From Wisconsin's Chequamegon-Nicolet to Michigan's Ottawa, Hiawatha, and Huron-Manistee, our Midwest national forests have important roadless areas that provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. These roadless areas are also an enormous resource for the recreation economy in the Midwest. We must not roll back protections for our public lands and must leave our last wild forests intact. Keep the Roadless Rule in place. Sincerely, Mr. Gregory Prosen 10 S348 Jamie Ln Willowbrook, IL 60527-6176 greg.prosen@gmail.com

The Trump Administration is taking away wild forest protections from our childern and future generations with its mindless, corrupt, and self-serving rollback of the Roadless Area Conservation Rule. This reward to political donors is a disgrace ?For more than two decades, this rule has protected much of the wildness that remains in our national forests. The protections have been particularly vital in the Midwest, where less than 200,000 acres of roadless, untrammeled forest lands survived the widespread logging of the past two centuries. I went to summer camp in Wisconsin's Chequamegon-Nicolet National Forest, which has important roadless areas that provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. Any politician who sits silent if this destruction proceeds is also entirely culpable Sincerely, Mr. Robert Johnston 623 W Oakdale Ave Chicago, IL 60657-5309 Bob.johnston1111@gmail.com (312) 402-8876

We need areas without roads. We need wildlife & silence to decompress. We need to protect our wild areas. Ioppose the rollback of the Roadless Area Conservation Rule. For more than two decades, this rule has protected much of the wildness that remains in our national forests. The protections have been particularly vital in the Midwest, where less than 200,000 acres of roadless, untrammeled forest lands survived the widespread logging of the past two centuries. We have very few natural areas here in Illinois. The Shawnee Forest & other areas in southern Illinois need protection. From Wisconsin's Chequamegon-Nicolet to Michigan's Ottawa, Hiawatha, and Huron-Manistee, the Midwest’s national forests have important roadless areas that provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. Trump wants to make these natural areas available for profiteering. Giving away our heritage for owners of mines, lumber, etc. These roadless areas are also an enormous resource for the recreation economy in the Midwest. Our roadless areas are worth more in recreational & tourist money than would be gained by the businesses trying to take our land for their profit. I urge you to stop rolling back protections for our public lands and leave our last wild forests intact. Please keep the Roadless Rule in place. Sincerely, Dr. Karlene Ramsdell 1124 Moorland Ave Shorewood, IL 60404-9618 2154ramsdell@gmail.com

I oppose the rollback of the Roadless Area Conservation Rule. For more than two decades, this rule has protected much of the wildness that remains in our national forests. The protections have been particularly vital in the Midwest, where less than 200,000 acres of roadless, untrammeled forest lands survived the widespread logging of the past two centuries. From Wisconsin's Chequamegon-Nicolet to Michigan's Ottawa, Hiawatha, and Huron-Manistee, the Midwest’s national forests have important roadless areas that provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. These roadless areas are also an enormous resource for the recreation economy in the Midwest. I urge you to stop rolling back protections for our public lands and leave our last wild forests intact. Please keep the Roadless Rule in place. Sincerely, Ms. Jennifer Smith 5820 N Sheridan Rd Apt 208 Chicago, IL 60660-4917 smithjj3@aol.com (312) 999-9999

I oppose the rollback of the Roadless Area Conservation Rule. For more than two decades, this rule has protected much of the wildness that remains in our national forests. The protections have been particularly vital in the Midwest, where less than 200,000 acres of roadless, untrammeled forest lands survived the widespread logging of the past two centuries. Shawnee National Forest is a particular gem with amazing landscape and biodiversity in a state that is mostly midwestern flat. It’s a place of quiet and beauty for those who need to touch base with nature after negotiating life in a hectic world. My visit there found people from Illinois and beyond of all ages and interests enjoying the National forest. This means these pristine lands are drawing tourist dollars and creating economic value - without adding more roads. I urge you to stop rolling back protections for our public lands and leave our last wild forests intact. Please keep the Roadless Rule in place. Sincerely, Ms. Kristin Faust 1444 S Federal St Unit H Chicago, IL 60605-3059 kfaust1960@aol.com

I oppose the rollback of the Roadless Area Conservation Rule. For more than two decades, this rule has protected much of the wildness that remains in our national forests. The protections have been particularly vital in the Midwest, where less than 200,000 acres of roadless, untrammeled forest lands survived the widespread logging of the past two centuries. From Wisconsin's Chequamegon-Nicolet to Michigan's Ottawa, Hiawatha, and Huron-Manistee, the Midwest’s national forests have important roadless areas that provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. These roadless areas are also an enormous resource for the recreation economy in the Midwest. I urge you to stop rolling back protections for our public lands and leave our last wild forests intact. Please keep the Roadless Rule in place. My grandchild is just now old enough to visit and appreciate our national forests and wilderness. It needs to be left intact for all of us and those who come afterwards.This attack is personal since it's in our home state of Illinois. KEEP the Roadless areas conservation Rule intact or STRENGTHEN it under federal law. Sincerely, Mrs. Joyce DeZutti 575 Woodlawn St Hoffman Estates, IL 60169-3028 jedezutti@yahoo.com (847) 285-1645

Dear Special Areas: Roadless Area Conservation, se01nsnn se01nsnn , As someone who cares deeply about national parks and the public lands that sustain them, I urge you to choose the No Action alternative and keep the Roadless Rule in place. For more than two decades, the rule has protected roughly 44.7 million acres of ecologically intact national forest lands, including areas near Yosemite, Yellowstone, and Great Smoky Mountains national parks. These wild places safeguard clean water, provide essential wildlife habitat, support outdoor recreation, and help keep park ecosystems connected and healthy. Rescinding the rule would expose these treasured landscapes to new roads and development, fragmenting habitat, degrading waterways, and putting our parks at risk. Many public lands are already available for timber and energy development. Roadless protections apply to only about 30% of National Forest lands, making these remaining intact areas especially important for future generations. Please do not move forward with this unnecessary rollback. Keep the Roadless Rule in place to protect the forests, wildlife, clean water, and the national parks. Once these lands are violated, they are gone forever. My grandkids and future generations will not be able to see and enjoy the beauty of this land and the wildlife that inhabits it. Please protect the these treasures that are a major part of what makes America special and great. April Smith 13901 W Meath Dr Homer Glen, IL 60491 Sincerely, April Smith

We need permanent protections for wildlife habitat and a peaceful refuge for people. I strongly oppose the rollback of the Roadless Area Conservation Rule and hope the government has the foresight to preserve what is left of our country's national forests. These roadless areas are also an enormous resource for the recreation economy in the Midwest. I urge you to stop rolling back protections for our public lands and leave our last wild forests intact. Please keep the Roadless Rule in place. Sincerely, Ms. Chris Kiel 310 Douglas Ave Waukegan, IL 60085-2042 christinekiel@icloud.com

I oppose the rollback of the Roadless Area Conservation Rule. For more than two decades, this rule has protected much of the wildness that remains in our national forests. The protections have been particularly vital in the Midwest, where less than 200,000 acres of roadless, untrammeled forest lands survived the widespread logging of the past two centuries. From Wisconsin's Chequamegon-Nicolet to Michigan's Ottawa, Hiawatha, and Huron-Manistee, the Midwest’s national forests have important roadless areas that provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. These roadless areas are also an enormous resource for the recreation economy in the Midwest. I urge you to stop rolling back protections for our public lands and leave our last wild forests intact. Please keep the Roadless Rule in place. Sincerely, Ms. Mary McClelland 1400 W Winnemac Ave Apt 1 Chicago, IL 60640-6811 Mary.McClelland@gmail.com (202) 253-2788

For more than two decades, the Roadless Area Conservation Rule has protected much of the wildness that remains in our national forests. The protections have been particularly vital in the Midwest. You may never have visited Wisconsin's Chequamegon-Nicolet or Michigan's Ottawa, Hiawatha, and Huron-Manistee, but the Midwest’s national forests have important roadless areas that clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. Hunters appreciate the fact that these areas provide a place for their prey to multiply. As these lands are an enormous resource for the recreation economy in the Midwest, on which hundreds of thousands of voters depend, I urge you to stop rolling back protections for our public lands and leave our last wild forests intact. Please keep the Roadless Rule in place. Sincerely, Ms. Anne Morse 3950 N Lake Shore Dr Chicago, IL 60613-3434 annie.mo57@gmail.com (773) 412-9233

I oppose the rollback of the Roadless Area Conservation Rule. For more than two decades, this rule has protected much of the wildness that remains in our national forests. The protections have been particularly vital in the Midwest, where less than 200,000 acres of roadless, untrammeled forest lands survived the widespread logging of the past two centuries. From Wisconsin's Chequamegon-Nicolet to Michigan's Ottawa, Hiawatha, and Huron-Manistee, the Midwest’s national forests have important roadless areas that provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. These roadless areas are also an enormous resource for the recreation economy in the Midwest. I urge you to stop rolling back protections for our public lands and leave our last wild forests intact. Please keep the Roadless Rule in place. Sincerely, Ms Grace van Kan 2635 W Rice St Apt 2 Chicago, IL 60622-5438 ghvankan@gmail.com (312) 286-2484

STOP DEVELOPERS FROM RUINING PROTECTED PUBLIC LANDS. ENOUGH! The Forest Service should keep the Roadless Rule intact exactly as it is, utilizing Alternative 1 in the current DEIS. I am deeply concerned about the proposal to rescind the Roadless Rule. Roadless areas provide important benefits to communities across the country, including clean drinking water, wildlife habitat, opportunities for outdoor recreation, and protection from the impacts of development. These lands are also an important part of the character and identity of many communities and provide places for people to hike, hunt, fish, camp, ski and otherwise enjoy the outdoors. I am particularly concerned that rescinding the Roadless Rule could increase development, reduce recreation opportunities, affect wildlife habitat, increase wildfire risk, or harm local economies that depend on outdoor recreation. The Roadless Rule has provided consistent, nationwide protections for these special places for decades. The Forest Service should not weaken those protections or open currently protected roadless lands to new development. I urge the Forest Service to pursue Alternative 1 and retain the existing Roadless Rule protections. Sincerely, RACHEL H FORSYTH-TUERCK 130 Fox Hunt Trl Barrington, IL 60010-3419 rach4syth@gmail.com

To Whom It May Concern, I am writing to express my vehement opposition to the U.S. Department of Agriculture (USDA) and Forest Service proposal to rescind the 2001 Roadless Area Conservation Rule. For twenty-five years, the Roadless Rule has provided a vital bedrock of protection for our nation's last remaining wildlands. Stripping these protections to prioritize industrial logging and road building under the guise of "local management flexibility" is short-sighted and ecologically disastrous. Crucially, the Forest Service has failed to adequately address how removing nationwide protections will result in severe, systemic violations of the Clean Water Act (CWA) and accelerate ecological degradation in vulnerable, fragmented ecosystems.1. Failure to Prevent Severe Degradation of Designated Uses (CWA Section 303) Under Section 303 of the Clean Water Act, states establish water quality standards based on the "designated uses" of a water body—such as drinking water supply, cold-water fisheries, and recreation. Inventoried Roadless Areas (IRAs) encompass the headwaters of countless pristine streams that supply clean drinking water to millions of Americans. The Impact: Introducing road construction and clear-cutting into these fragile headwaters will cause immediate, severe soil erosion. The resultant massive influx of silt, sediment, and industrial debris will directly choke out cold-water aquatic habitats, violating state anti-degradation policies and destroying municipal water source standards.2. Unregulated Nonpoint Source Pollution (CWA Section 319)Forest roads are well-documented by science as the primary source of human-caused sediment pollution in national forests.The Impact: Roads fundamentally alter natural hydrology. They intercept subsurface water flow, accelerate surface runoff, and act as direct conduits for sediment, heavy metals, and petrochemicals into nearby streams. By removing the 2001 prohibition, the Forest Service will trigger an unmanageable surge in nonpoint source pollution, actively undermining state management programs funded and mandated under Section 319 of the CWA to control runoff.3. Regional Focus: Irreparable Harm to the Shawnee National Forest (Illinois)The proposed rescission will have devastating, irreversible impacts on fragmented Eastern forests like the Shawnee National Forest in southern Illinois. Severe Sedimentation in Critical Watersheds: The topography of southern Illinois features highly erodible loess soils on steep slopes. Removing roadless protections will greenlight heavy machinery and logging road construction that will trigger severe soil erosion. This runoff will rapidly impair critical local watersheds—including the Belle Smith Springs and Morris Creek areas—violating state anti-degradation standards under the Clean Water Act. Microclimate Disruption and Rising Soil Temperatures: Industrial logging removes the protective overhead canopy, exposing the forest floor to direct solar radiation. In southern Illinois's increasingly hot summer climate, this canopy loss will cause a severe spike in soil temperatures and a drastic reduction in soil moisture. High soil temperatures directly compromise the forest's ability to filter water, accelerating the degradation of local aquatic ecosystems. Compounding Wildfire Risks: The combination of decreased soil moisture, desiccated forest floors, and the introduction of dry, highly combustible logging slash creates a powder keg. By carving new road corridors into the forest, the agency introduces fresh vectors for human-caused ignitions, significantly elevating the risk of catastrophic wildfire in a region adjacent to rural communities. Threats to Protected Species: Stripping nationwide roadless protections removes a critical legal backstop, leaving fragile habitats—including the oak-hickory forests and endangered Indiana bat roosting areas—vulnerable to piecemeal industrial exploitation without proper cumulative impact analysis. Conclusion and Action Requested The Forest Service already faces a massive multi-billion-dollar backlog in maintaining its existing 370,000 miles of roads. Adding more roads will only worsen water pollution, elevate wildfire risks, and fragment critical habitats. Before taking any final action, the USDA must: Conduct a rigorous, granular environmental analysis mapping the exact water quality impacts on downstream communities. Formally guarantee that no pristine watershed or CWA-protected water body will experience degraded water quality. Withdraw this proposed rule entirely and permanently uphold the protections of the 2001 Roadless Rule. Thank you for considering these substantive comments. Sincerely,[ GLENN DAVID MCLERNON ILLINOIS REGISTERED LANDSCAPE ARCHITECT/LANDSCAPE ECOLOGIST MURPHYSBORO, IL 62966 MCLERNONGLENN@MSN.COM

Dear Special Areas: Roadless Area Conservation, I urge the U.S. Forest Service to keep intact the existing Roadless Area Conservation Rule (“Roadless Rule”), which protects nearly 45 million acres of our nation's forests and grasslands. Prior to the rule's implementation in 2001, industrial logging and accompanying roadbuilding disrupted and destroyed 3.2 million acres of fragile habitat annually while also degrading clean water supplies and limiting outdoor recreation opportunities. For a quarter century, the Roadless Rule has protected ecologically sensitive landscapes, wildlife populations and habitat, and communities dependent upon their services. The rule protects countless wild animals, including imperiled species who rely on intact habitats for survival. Additionally, these lands provide clean water and support numerous recreational activities that sustain local jobs and economies. The rule allows for flexibility in resource management, with exceptions for vegetation management and road construction projects in the interest of public health and safety. The American public overwhelmingly supports the Roadless Rule; recent bipartisan polling shows that 77% of voters support conserving roadless lands. Indeed, the rule was created with input from over 1.6 million comments and, in September, over half a million Americans responded to the U.S. Forest Service's notice of intent to repeal the Roadless Rule with comments voicing strong opposition. We have made our opinion clear time and time again–our public lands should remain public, not be degraded for the interests of private industry. I strongly urge the U.S. Forest Service not to repeal the Roadless Rule, as keeping the rule intact will protect our shared forestlands for generations to come. russ Russ Ziegler 22w 61st Street, Willowbrook, Downers Grove Township, IL, USA, IL 60516 Sincerely, Mr. russ Russ Ziegler

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Wildlife, watersheds and forests are part of our ecosystem's balance and weather patterns, and that balance depends on land the agency still has the power to protect. Rescinding the 2001 Roadless Area Conservation Rule threatens to undo what the National Park and Forest Systems were built to do: conserve the natural beauty of this country so that all can enjoy it. I oppose this rescission fully, and I ask the agency to answer the specific questions I raise below. The proposal uses wildfire and fuels management as part of its rationale, but the agency's own record says the opposite of what that rationale implies. The agency's own text 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." If the agency's own data show that roads increase ignition risk rather than reduce it, the wildfire argument for rescission collapses under the agency's own evidence. I ask that the agency explain, with citations to the record, why the proposal departs from these prior findings and how it reconciles the rescission with the fire density data in its own draft environmental impact statement. The economic case for rescission is no stronger. 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." These are not the numbers of a national economic emergency. Yet the proposal would open roads into country that has none, at the expense of recreation values and water protection, while the agency is already carrying a maintenance backlog of $6.9 billion against a road budget of roughly $73 million a year. If current roads cannot be maintained, it makes no sense to develop more. Improve what is already in place. The agency must reconcile the proposal with its own cost-benefit analysis, which projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. How does an action whose own analysis cannot establish a net benefit justify expanding a road network the agency already cannot afford to maintain? The proposal also argues that state-by-state approaches can replace a national rule, but the agency has been down that road before and found it wanting. Its own record reflects 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 courts did not accept that reasoning the last time the agency substituted local decision-making for the national rule. I ask that the agency address its own prior finding that local approaches can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies that doomed the earlier state-by-state attempt. On the question of statutory authority, the agency has also already received a definitive answer. The Tenth Circuit reviewed the 2001 rule and 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 rule within the authority Congress granted. The agency must explain, with specific legal grounding, the basis for any position that the 2001 rule exceeded that authority, given that federal appellate review already went the other way. More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas, and the agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. American citizens rely on clean water for drinking, farming, and food. Water systems are already deteriorating, and opening these areas to roads and the sediment they carry will make that worse. The agency held more than 600 public meetings and received 1.6 million comments before writing this rule. It has held none to undo it. We need to protect these resources and this land for our children and for the future of our ecological systems. Please do not create more endangered species and more impaired watersheds when the record already tells you what roads do. The agency must state on the record what public process it believes satisfies its obligations here, and why that process is adequate. Sincerely, Mary Pat Starnes 46 Robin Hill Drive Naperville, IL 60540-7317

I oppose the rollback of the Roadless Area Conservation Rule. For more than two decades, this rule has protected much of the wildness that remains in our national forests. The protections have been particularly vital in the Midwest, where less than 200,000 acres of roadless, untrammeled forest lands survived the widespread logging of the past two centuries. From Wisconsin's Chequamegon-Nicolet to Michigan's Ottawa, Hiawatha, and Huron-Manistee, the Midwest’s national forests have important roadless areas that provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. These roadless areas are also an enormous resource for the recreation economy in the Midwest. I urge you to stop rolling back protections for our public lands and leave our last wild forests intact. Please keep the Roadless Rule in place. Sincerely, Ms. Judith Nemes 35 Ewacker Dr Chicago, IL 60601 jnemes@elpc.org (773) 892-7494