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I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Upper Bald River (9,202 acres), Cherokee NF, Tennessee - Joyce Kilmer Slickrock Add. (1,396 acres), Cherokee NF, Tennessee 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: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. 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. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Issue 2: Reliance interests are invited and never assessed I plan trips into these areas year after year, counting on the protection that keeps them what they are. That reliance is exactly what the agency asked commenters to describe. 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. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Issue 3: The agency's own fire data cuts against the proposal I hike and camp in this country, and fire shapes every trip I plan. If the agency's own data ties ignitions to road access, I want that weighed honestly. 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. The effects analysis itself concedes that road access could increase the number and frequency of wildfires. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard. Issue 4: 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 5: Elk survival, in the agency's own citation I watch wildlife, and the animals I go looking for need country roads have not reached. The agency's own citation makes that point better than I can. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. It may come as a surprise to the Forest Service that yes, elk are populating the Cherokee National Forest. No population-level effect on big game is projected anywhere in the document. I ask that the agency project the effects on big game populations and hunter opportunity. 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, Axel Ringe 1940 Lafayette Road New Market, TN 37820

Docket ID: FS-2025-0001 Proposed Action: Rescission of the 2001 Roadless Area Conservation Rule To the U.S. Forest Service and Secretary Brooke Rollins: I am writing to formally submit my strong opposition to the proposed full rescission of the 2001 Roadless Area Conservation Rule across America’s National Forest System lands. The 2001 Roadless Rule has successfully protected over 44 million acres of roadless wildlands for nearly 25 years. Rescinding this national policy under the justification of wildfire mitigation is ecologically negligent and fiscally irresponsible for the following reasons: 1. Increased Ignition Risks: Peer-reviewed wildland fire research shows that up to 80–90% of all wildfires are caused by human activity, with ignitions occurring up to four times more frequently near roads than in unfragmented backcountry. Carving new road networks into remote forests will exponentially increase the likelihood of human-caused ignitions. 2. Current Solution: I have personally had conversations with firefighters and individuals with advanced degrees in public land management, and the current process of dropping in firefighters already speaks to the proposed argument for roads in these lands. Because of the ability to drop firefighters in via helicopter, it negates the need to build roads to manage fires in these areas. Furthermore, I have come to appreciate alternative fire management techniques such as native burning rituals which provide much less pollution and promote biodiversity within these regions. 3. Existing Rule Flexibility: The 2001 Roadless Rule already contains clear exceptions allowing land managers to address urgent public health, safety, and catastrophic wildfire threats. Forest Service personnel can already conduct mechanical thinning, controlled burns, and emergency interventions without permanently destroying these precious resources. 4. Drinking Water and Watershed Degradation: Roadless areas serve as the natural municipal water filtration systems for roughly 47 million Americans. Constructing roads and conducting commercial harvests in steep backcountry areas causes severe soil erosion, sedimentation, and silt pollution in downstream headwaters. 5. Infrastructure Backlog: The U.S. Forest Service already faces a multi-billion-dollar deferred road maintenance backlog on more than 370,000 miles of existing roads. Authorizing new road construction when existing infrastructure cannot be maintained places an unnecessary burden on American taxpayers. As an avid backpacker who regularly visits national parks and forests, I rely on these intact roadless areas for clean watersheds, wildlife migration corridors and undisturbed tranquility in the backcountry. I strongly urge the Department of Agriculture and the U.S. Forest Service to withdraw this proposed rescission in its entirety and uphold the 2001 Roadless Area Conservation Rule. Sincerely, Mark Mitchell Bartlett, TN 38134

I want to express my strong opposition to the rescission of this Rule. A resident of East Tennessee,I live adjacent to USFS lands that are being logged. Ì acknowledge the need for timber and forest management. However the Roadless Areas were set apart for their value as healthy ecosystems, wildlife habitat and places for primitive recreation. Often tracts now covered by the Rule are roadless precisely because they are less accessible or on steep, rocky land. Cutting trees in these areas will increase the likelihood of landslides and flooding. In Tennessee and North Carolina we sustained damage to more than 190,000 acres of our National Forests from Hurricane Helene. Removing more trees increases the risk for forest damaging flooding in downstream communities. I urge you to reconsider the rescission of the Roadless Areas Conservation Rule in order to protect us from continuing damaging flooding with increased costs of recovery which impact all taxpayers. Anne Anderson 520 Copeland Rd Ocoee, TN 37361

Re: Docket FS-2025-0001Sept 9, 2026 Comments: Intent to Prepare An Environmental Impact Statement I am writing to express my strong opposition to the rescinding of the 2001 Roadless Rule. My wife and I are residence of New Mexico and we immensely appreciate the natural beauty of this state. The argument that a national approach taken in 2001 roadless rule is no longer necessary does not support conservation practices and the will of the people. Given the Trump's administration attitude towards reducing environmental protections makes this rescission proposal is unacceptable and egregious. We support the ‘no action’ alternative that would retain the 2001 Roadless Rule. Lin Cameron 482 Tennessee Ave Sewanee, TN 37375

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests near my home in the foothills of the Great Smoky Mountains provide something that cannot be replaced or rebuilt. I hike and camp there to find quiet and to rejuvenate. I have also seen what fire can do in that landscape, and I take the wildfire question seriously. That is exactly why the agency's reasoning on fire troubles me as much as anything else in this proposal. 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." Living where I do, in country that knows fire, I read that finding and I cannot understand how an agency that wrote those words now proposes to open roadless areas to road construction as a wildfire management tool. I ask the agency to explain why this proposal departs from its own prior findings on fire occurrence in roadless areas, and to reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is equally hard to follow. The agency's 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." That is the agency's own characterization of the stakes on the extraction side. Against that, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. A range that wide, spanning a net loss to a net gain, cannot establish that the action produces a benefit. The agency has not explained how it justifies expanding a road system already carrying a $6.9 billion maintenance backlog on the strength of an economic analysis this uncertain. I ask it to do so, in plain terms, on the record. Public land is an irreplaceable resource, and the way alternatives were screened here raises a direct procedural problem. The agency's own record reflects that alternatives offering more protection were dismissed as not responsive to deregulatory executive orders, and that the option of keeping roadless boundaries was cut because it "would continue to restrict local decision-making discretion" and because analysing roadless values is "an administrative and legal burden for the agency." A purpose and need written as deregulation forecloses the environmental comparison that the National Environmental Policy Act exists to require. When the purpose excludes protection by definition, no protective alternative can survive the screening, and the public never sees the comparison. The agency should restate the purpose and need in terms of actual forest conditions and analyse at least one protective alternative in full. Finally, the wildfire rationale and the stated legal basis of the proposal do not fit together. The agency states that "the purpose and need is to reduce regulatory burden and return decisionmaking to local officials," and it also states that overlap with the wildland-urban interface as defined by the Healthy Forests Restoration Act is 9.8 million acres, 24 percent of the affected area, and that the benefits of added fuel-management access "would likely be modest and localized." The agency itself constructed and then rejected a targeted alternative limited to wildland-urban interface areas, an alternative that would have addressed the fire rationale without rescinding protections across the full area. Nationwide rescission goes far beyond what the fire argument, even if accepted at face value, could support. The agency needs to explain why it chose nationwide rescission over the more limited alternative it built and rejected. I manage to find quiet in those forests, and I want future generations to have what I have found there. That is not a recoverable thing once roads go in. These are not abstract concerns. Sincerely, Sue DuBois Walland, TN 37886