Read the comments.

Dear Regulators As a life-long lover of both roads and forests, I am writing to strongly reject repealing the 2001 "Roadless Rule". I understand that this rule was put in place to protect vital habitats across the United States - and to slow the spread of development and deforestation. In my lifetime, I have seen how one road can lead to many roads which then create a criss-cross effect that breaks up and ultimately destroys habitats. I have seen water rights extended to commercial operators in National Forests - with roads and pipelines damaging the ecosystem and taxpayers footing the bill for their access. I do not believe local forest leaders should be able to remove protections from these designated lands - overseeing their activities would be costly and complicated - who would provide oversight or enforcement of local protections? • The Proposal: The U.S. Department of Agriculture (USDA) and U.S. Forest Service proposed repealing the 2001 rule, which protects roughly 45 to 58.5 million acres of inventoried roadless national forest lands from most commercial logging and new road construction. • The Administration's Rationale: Proponents of the repeal argue it will reduce regulatory burdens, transfer management flexibility to local forest leaders, and help mitigate severe wildfire risks and insect outbreaks through active forest management. Removing national protections threatens critical wildlife habitats, compromises clean drinking water sources for millions of Americans, and could increase wildfire risks by opening remote backcountry areas to commercial activities. If you are truly concerned about mitigating severe wildfire risks, then consider a different kind of de-regulation: one in which the First People lead the management of these forests - this would achieve the same result, transferring national control to regionally-relavant managers, while still maintaining a cohesive protection that extends across all National Forests. The federal government would still provide oversight and enforcement, but local indigenous management would be able to steward the forests regionally. Thank you for your consideration, J. DIDIER, Los Angeles, CA

Do NOT change the roadless rule. If you really care about protecting the forests, reverse the DOGE and Trump administration cuts of nearly 6,000 U.S. Forest Service workers, slashed budgets of $438 million, and paused critical wildfire prevention funds they carried out in early 2025.

I write in strong support of the U.S. Department of Agriculture’s proposed rule to rescind the 2001 Roadless Area Conservation Rule in its entirety. This one-size-fits-all national restriction has constrained local forest managers for 25 years, limiting timely access for active management, hazardous fuels reduction, and wildfire response across more than 44 million acres of National Forest System lands. Rescinding the rule restores decision-making authority to the local level through existing land management planning processes under the National Forest Management Act, without mandating any particular road construction or timber harvest. This change is especially important for communities like those in Skamania County, Washington, which border and depend on the Gifford Pinchot National Forest. The Gifford Pinchot contains substantial inventoried roadless areas (approximately 213,000 acres based on Forest Service inventory data). These lands sit amid a landscape that has faced elevated wildfire risk, including recent high and very high fire danger ratings, fire restrictions, and incidents such as the Backbone, and High Lava fires. Local officials in Skamania County have highlighted the heavy fuel loads on the forest and the need for strategic fuel breaks and treatments to protect communities, infrastructure, and residual old-growth and wildlife habitat from catastrophic fire. The Roadless Rule has restricted road construction and reconstruction needed for efficient access to conduct thinning, prescribed fire, and other fuels treatments in many of these areas. Forest Service data indicate that more than 40 percent of inventoried roadless areas nationwide carry high or very high wildfire hazard potential, yet only about 5 percent have received hazardous fuels reduction treatments since 2014. A significant portion of these lands already lie near existing roads. Removing the national prohibition gives Gifford Pinchot managers the flexibility to evaluate site-specific needs—improving firefighter access, reducing response times, creating defensible space near communities and critical infrastructure, and treating fuels before they accumulate into extreme fire behavior—while still operating under full NEPA review, forest plans, and other environmental laws. For Skamania County residents, the stakes are practical and immediate: safer communities, reduced risk of large, destructive fires that threaten homes, water supplies, recreation, and local economies, and the ability for the Forest Service to manage the land based on current conditions rather than a 25-year-old blanket restriction. Active management is essential to restoring forest health and resilience in the Cascades. I urge the Department to finalize the full rescission of the 2001 Roadless Rule. Returning authority to local national forest managers will better enable the Gifford Pinchot National Forest and similar forests across the West to address wildfire risk, protect neighboring communities such as those in Skamania County, and sustain the multiple uses and values these public lands provide. Thank you for the opportunity to comment and for prioritizing practical, science-informed forest management. Sincerely, Asa Leckie asal00@msn.com

Having lived in the mountains and the west most of my life I understand that balance between multiple use access and conservation. This rule should stand in its existing form and if changes should be needed those need to be made at the local level, recinding in its entirety leaves too much open to the unknown.

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66). The Roadless Rule provides a clear, consistent standard for protecting national forest lands that have remained largely free from road construction. Rescinding the entire rule is unnecessarily broad when the Forest Service already has tools to address specific needs such as wildfire mitigation, forest restoration, public safety, and other necessary management activities. I am particularly concerned about the practical consequences of allowing additional road construction in currently roadless areas. New roads fragment wildlife habitat, increase erosion and sediment runoff into streams, and create continuing maintenance costs. They can also permanently alter areas valued for hiking, hunting, fishing, recreation, clean water, and their undeveloped character. These concerns are especially relevant in North Carolina and the Southern Appalachians, where national forests protect important watersheds and biologically diverse ecosystems and support local recreation and tourism. If the Forest Service believes changes to the existing rule are necessary, it should address demonstrated management problems through targeted modifications rather than eliminating nationwide protections altogether. I ask the Forest Service to consider the environmental, fiscal, and long-term consequences of rescission and retain the Roadless Area Conservation Rule.

Under Secretary Boren Chief Schultz Secretary Rollins I am writing to ask you to support the “No Action Alternative” regarding eliminating the Roadless Rule Recission. After retiring from working for the USFS for 30 years I would love to go into the reasons why I am asking this but this Administration is short on Science/facts & long on stupid so I feel I’s be wasting my time; besides, I believe the die has been cast & the decision already made. However, I want my name to go on the record as opposing eliminating the Roadless Rule. FYI – I am a member of the Backcountry Hunters & Anglers, the National Association of Forest Service Retirees & the National Parks Conservation Association.

I heavily oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would result in the destruction of America's public lands. It would undermine the protections we have in place for these forests, clean water, and wildlife refuges. And, it would severely impact recreational opportunities that enrich the lives of millions of Americans. As an American who takes great pride in the beauty of nature we have managed to protect thus far, I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. My name is Dawson Autry and I live in The Colony, Texas. While this rule does not affect my daily life at home, it does affect millions of Americans, trees, and wildlife who depend on the areas that this rule protects. These areas have countless benefits and reasons to keep them protected under federal roadless rule, whether it be protection of clean drinking water, protection of animal habitats, economic benefits from tourism, or improved mental health benefits by providing recreational forested areas. The pride that the American people have in a government that protects its forests cannot be understated. These are areas I travel to often to visit in Washington, Oregon, and California. There are many more states, parks, and forests I wish to visit in my lifetime, precisely because they are protected and cared for by rules like the Roadless Area Conservation Rule. I sincerely hope that my children and all future generations of Americans would get that same opportunity. Short term benefits are not worth sacrificing these areas for, these areas must be protected with everything we have. On January 12, 2001, the Forest Service promulgated the Roadless Area Conservation Rule (66 FR 3244) at 36 CFR 294 Subpart B to provide long-term protection for 58.5 million acres of inventoried roadless areas across the National Forest System. The stated "Rationale for the Proposal" does not at all adequately install proper protections for these areas in equal to what the Roadless Area Conservation Rule provides at a federal level. To quantify a single case, under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections. That is one state losing protection for over 1 million acres. When you widen the impact of removing this rule to other states as well, the impact is truly massive and truly horrifying. The Summary of Potential Impacts section states some benefits to the removal of the Roadless Area Conservation Rules. Namely, items such as: 1. "Rescinding the 2001 Roadless Rule would increase opportunities for hazardous fuel treatments in the wildland-urban interface, where 9.8 million acres (or 24 percent) overlap with inventoried roadless areas, and, where justified, would allow strategically placed roads that can improve suppression effectiveness near communities and critical infrastructure." 2. "This expansion could increase road-based recreation and accessibility improvements..." 3. "Management Flexibility" 4. Economic gains like increased timber and "access for minerals or energy uses" While I can understand that there may have been some good intention behind the proposal, I want to stress the importance that the broad removal of a federal protection is not the way to achieve these goals. Loss of federal protection will simply result in the gradual erasure of the 18.2 million acres that this rule protects. That is natural land that will either be sold away to corporations or cut-through and paved over with roads. That is natural land that America and the wildlife who inhabited it will never get back. Your proposal has already mentioned several of the environmental and economic impacts that the removal of this rule can cause. It also places a price on these impacts. I urge you to look beyond the bottom line and the immediate price these actions may cause, because the ramifications of removing protections on such a broad scale are much, much greater, and the effects will be felt each and every year from the day they are removed. This is an action that will affect all future generations of Americans. By removing this rule, we would potentially be sacrificing their futures to enjoy the beautiful lands of the United States of America. America is beautiful and deserves to be protected. Once again I strongly urge you to reconsider. Fully or partially removing the Roadless Area Conservation Rule would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

I am firmly against USDA's proposal to revoke the 2001 Roadless Rule. Roadless national forests represent some of the last untouched public forest landscapes we have. They safeguard clean drinking water, wildlife habitats, salmon streams, ancient forests, outdoor activities, and essential areas for communities, Tribal Nations, and future generations. Once these areas are cut by new roads, logging, and industrial activities, the destruction is irreversible. The USDA should not eliminate a national protection that has shielded roadless forests for over 20 years. The existing Roadless Rule already permits necessary activities to mitigate wildfire risk, so repealing it is unnecessary for community safety. In fact, more roads can lead to greater risks of human-caused fires, habitat fragmentation, erosion, and increased long-term management costs. I am also worried that rescinding the rule would place protection decisions in local forest planning processes, making intact forests more prone to political pressure and short-term resource extraction. Public forests should be managed for clean water, biodiversity, climate resilience, Indigenous stewardship, and public benefit, not opened to more roadbuilding and logging. Please withdraw the proposed repeal, maintain the 2001 Roadless Rule, and choose the strongest option to protect roadless areas throughout the National Forest System. Thank you for considering my comment.

Submit your public comment against the repeal of the Roadless Rule. You can use the following comment: I am firmly against USDA's proposal to revoke the 2001 Roadless Rule. Roadless national forests represent some of the last untouched public forest landscapes. They safeguard clean drinking water, wildlife habitats, salmon streams, old-growth forests, outdoor recreation areas, and essential places for communities, Tribal Nations, and future generations. Once roads, logging, and industrial activities fragment these areas, the harm cannot simply be reversed. USDA should maintain this national protection that has shielded roadless forests for over 20 years. The existing Roadless Rule permits necessary work to mitigate wildfire risks, so repealing it is unnecessary for community safety. In fact, adding more roads could lead to increased human ignition risks, habitat fragmentation, erosion, and long-term management costs. I am also concerned that rescinding the rule would delegate protection decisions to local forest planning processes, making intact forests more susceptible to political pressure and short-term exploitation. Public forests should be managed for clean water, biodiversity, climate resilience, Indigenous stewardship, and public benefit, not subjected to more roadbuilding and logging. Please withdraw the proposed repeal, uphold the 2001 Roadless Rule, and choose the strongest option to protect roadless areas throughout the National Forest System. Thank you for considering my comment.

America's National Parks, National Forests, National Wildlife Refuges, and other related lands are the property of all United States citizens. They are preserved as wild spaces by and for the people of this country. The agencies that have been tasked with their care and oversight are not given the right to simply start using these assets for whatever they want. It would be like a bank manager going into the safety deposit boxes and simply taking what they wanted or melting down all the gold to make a super tacky sculpture for the lobby. I think most people can agree that this would never be allowed. That manager would be personally liable and almost certainly have some prison time coming. Similarly, just because you hold a position as an employee paid by the citizens of the United States, in no way way does that give you the right to start pilfering our assets and passing them to your golfing buddies. Millions of people are watching you try to steal what isn't yours. We can see the difference between good management and theft. And just like that tacky gold statue, destroying assets that bring in millions of dollars every year to the surrounding communities is not good management. It's wildly shortsighted and serves only to benefit a very select few. We see what you are doing. And so even if you can't personally understand the myriad benefits that millions of people flock to their parks for, understand that what you are proposing is simply a very visible means to theft.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 We are already seeing what happens when we use too many resources. Let's back off taking from the earth for awhile. Water from national forest country in the Pacific Southwest Region reaches as many as 2,264,400 people downstream, by the agency's own data. My tap may be one of them. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The substance of round one is never answered I commented in the first round, and I have read what the agency says it did with everything we sent. Its own account describes counting, not answering: By the agency's own count, over 220,000 comment letters were received, representing over 625,000 submissions, and approximately 99 percent were generally opposed to the rescission. The DEIS says the comments helped inform the alternatives and identifies no issue that changed anything. Counting comments is not responding to them. I ask that the agency state which substantive issues from the first comment period altered the proposal, and which were rejected and why. Issue 2: Tribal consultation is incomplete and its summary is withheld from comment I commented in the first round and waited to be heard. By the agency's own record, others owed a far more formal hearing are still waiting too: The Forest Service received 64 requests for Tribal consultation; 29 consultations have been held and 5 more scheduled, with the published Tribal Summary Impact Statement records that the majority sentiment among consulted Tribal governments is opposition, viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival and the ecological health of ancestral homelands; the final Tribal Impact Summary Statement is deferred to the final rule. Tribal governments proposed alternatives, including a strengthened roadless rule and a Traditional Homelands Conservation Rule, and none was analysed; the final impact statement arrives only when comment is closed. I ask that the agency complete all 64 requested consultations and publish the Tribal Impact Summary Statement for public comment before any final rule. Issue 3: Every conservation alternative was eliminated by how the purpose was written I took the time to comment before, and I expected the alternatives to reflect what the public asked for. The agency's own document shows how it wrote every protective option out of consideration: Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option 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 written as deregulation forecloses the comparison NEPA requires. I ask that the agency restate the purpose and need in terms of forest conditions and analyse at least one protective alternative in full. Issue 4: Reliance interests are invited and never assessed How this reaches me is stated above in my own words, and that is a reliance interest. The agency asked for exactly this and then weighed none of it: 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. 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. 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, Brenna Geehan San Francisco, CA

These lands belong to citizens of the United States, not to corporations which have historically, and irreparably, extracted every resource possible at the expense of the environment and every one of us who relies upon it for a good life. Repealing the Roadless Rule puts Americans at greater risk from the deleterious effects of climate change--most pressingly wildfires--and would ostensibly eliminate access to many of our most precious places for recreation. This administration's thinly-veiled policy of enriching a handful of its most sycophantic supporters and their family members at the expense of the vast majority of taxpaying americans is blatantly corrupt and a betrayal of the American people. Do not repeal the roadless rule.

I heavily oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would result in the destruction of America's public lands. It would undermine the protections we have in place for these forests, clean water, and wildlife refuges. And, it would severely impact recreational opportunities that enrich the lives of millions of Americans. As an American who takes great pride in the beauty of nature we have managed to protect thus far, I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. I live in The Colony, Texas. While this rule does not affect my daily life at home, it does affect millions of Americans, trees, and wildlife who depend on the areas that this rule protects. These areas have countless benefits and reasons to keep them protected under federal roadless rule, whether it be protection of clean drinking water, protection of animal habitats, economic benefits from tourism, or improved mental health benefits by providing recreational forested areas. The pride that the American people have in a government that protects its forests cannot be understated. These are areas I travel to often to visit in Washington, Oregon, and California. There are many more states, parks, and forests I wish to visit in my lifetime, precisely because they are protected and cared for by rules like the Roadless Area Conservation Rule. I sincerely hope that my children and all future generations of Americans would get that same opportunity. Short term benefits are not worth sacrificing these areas for, these areas must be protected with everything we have. On January 12, 2001, the Forest Service promulgated the Roadless Area Conservation Rule (66 FR 3244) at 36 CFR 294 Subpart B to provide long-term protection for 58.5 million acres of inventoried roadless areas across the National Forest System. The stated "Rationale for the Proposal" does not at all adequately install proper protections for these areas in equal to what the Roadless Area Conservation Rule provides at a federal level. To quantify a single case, under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections. That is one state losing protection for over 1 million acres. When you widen the impact of removing this rule to other states as well, the impact is truly massive and truly horrifying. The Summary of Potential Impacts section states some benefits to the removal of the Roadless Area Conservation Rules. Namely, items such as: 1. "Rescinding the 2001 Roadless Rule would increase opportunities for hazardous fuel treatments in the wildland-urban interface, where 9.8 million acres (or 24 percent) overlap with inventoried roadless areas, and, where justified, would allow strategically placed roads that can improve suppression effectiveness near communities and critical infrastructure." 2. "This expansion could increase road-based recreation and accessibility improvements..." 3. "Management Flexibility" 4. Economic gains like increased timber and "access for minerals or energy uses" While I can understand that there may have been some good intention behind the proposal, I want to stress the importance that the broad removal of a federal protection is not the way to achieve these goals. Loss of federal protection will simply result in the gradual erasure of the 18.2 million acres that this rule protects. That is natural land that will either be sold away to corporations or cut-through and paved over with roads. That is natural land that America and the wildlife who inhabited it will never get back. Your proposal has already mentioned several of the environmental and economic impacts that the removal of this rule can cause. It also places a price on these impacts. I urge you to look beyond the bottom line and the immediate price these actions may cause, because the ramifications of removing protections on such a broad scale are much, much greater, and the effects will be felt each and every year from the day they are removed. This is an action that will affect all future generations of Americans. By removing this rule, we would potentially be sacrificing their futures to enjoy the beautiful lands of the United States of America. America is beautiful and deserves to be protected. Once again I strongly urge you to reconsider. Fully or partially removing the Roadless Area Conservation Rule would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

Large, intact ecosystems, such at the roadless areas, offer numerous benefits. Obviously, there are conservation benefits to fauna who need tracts of land undisturbed by humans. From an anthropomorphic point of view, intact ecosystems support the nature capital that we all depend upon. In other words, without nature, we all perish. That alone should be sufficient reason to ensure we continue to have roadless areas in our public lands. Getting rid of the legislation that protect roadless areas is a miserable, stupid idea. Please do not go ahead with such legislation. Thank you. CYoung

Dear Special Areas: Roadless Area Conservation, se01nsnn se01nsnn , I urge you to keep the Roadless Rule in place (choose the No Action alternative.) As Americans, it is our patriotic and more importantly moral duty to safeguard these sacred lands from exploitation by the privileged few who would rip up every last tree, pollute every body of water and who otherwise seek to endanger and destroy every living creature (including human life) and every precious ecosystem that the Earth has given us. It is our god-ordained duty to steadfastly stand in the way of the regressive spirit of those who seek to destroy and exploit the natural beauty and life of this great nation, only for the purpose of gross profit and greed, at the expense of current and future generations of Americans and all people of this planet Earth. Keep the Roadless Rule! Thank you. Eric Heming 2071 S Fox St Denver, CO 80223 Sincerely, Eric Heming

I am a 37-year-old Wyoming native and a lifelong lover of the outdoors, nature and wild places. Throughout my life I have enjoyed the empty places on the map for the simple fact that they are still wild and I would like to see them stay that way. For these reasons, I would ask that the USDA pursue Alternative 1, No Action.

I strongly oppose the USDA’s proposal to eliminate, weaken, or alter the Roadless Rule. For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. As stated in the Draft Environmental Impact Report (DEIS), the Rationale for the Proposed Rule is to reinstate “….important management tools for key areas where there are needs or opportunities to address overgrown and fuel-loaded national forests.” Essentially, repealing the 2001 Roadless Rule will allow the construction of roads to facilitate management of overgrown and fuel-loaded national forests. However, the Department’s own analysis indicates that it will have the opposite effect. Page 85 of the DEIS states that “Past research and new analyses presented here indicate that more fires, both in absolute numbers and density, originate on other NFS lands compared to IRAs and wilderness areas. The DEIS goes on to state that “The proportion of human-caused fires in IRAs and wilderness is less than half that on other NFS lands, which may be due in part to public access limitations. The incidence of human-caused fires generally increases with proximity to roads.” Furthermore, the DEIS states that “the new analysis presented in this DEIS indicates that other NFS lands also have about twice the density of natural ignitions than IRAs or wilderness, potentially due to biophysical differences or higher detection rates. The number of “actionable” and reportable wildfires may also be generally greater in areas outside of roadless or wilderness areas.” The DEIS fails to analyze the economic benefits and reduced negative impacts of focusing management actions on “other NFS lands” compared to IRAs and wilderness area. As stated on page 26 of the DEIS, “Alternatives analyzed in detail must be technically and economically feasible and meet the purpose and need (NEPA section 102 (2 (c)(iii)), 7 CFR 1b.7(h)). Analyzing increased management of “other NFS lands” is technically and economically feasible and meets the purpose and need of “reducing regulatory burden” and providing “management flexibility”. For these reasons, I believe the Department has failed to comply with NEPA, and the 2001 Roadless Rule should remain in place until an additional alternative (increased management of other NFS lands) is fully analyzed. Sincerely, Jeff Stephens OR

We need our roadless rules to remain in place. The forests do not belong to us or to be owned by us. We share this life with nature and all of nature have rights to live. To thrive. Please don't cross this line. We have so much to repair.

re:%20Rescission%20of%20the%20Roadless%20Area%20Conservation%20Rule,%20Docket%20FS-2025-0001%0A%0AMy%20family%20hikes%20and%20camps%20all%20over%20the%20country,%20and%20in%20my%20state%20I%20go%20looking%20for%20fox,%20owl,%20and%20wild%20turkey.%20The%20beauty%20of%20untouched%20nature%20is%20something%20I%20believe%20should%20be%20valued%20and%20protected.%20The%20proposed%20rescission%20of%20the%202001%20Roadless%20Area%20Conservation%20Rule%20threatens%20both,%20and%20I%20ask%20the%20agency%20to%20answer%20the%20specific%20concerns%20below.%0A%0AThe%20wild%20turkey%20I%20look%20for%20depends%20on%20exactly%20the%20kind%20of%20habitat%20roadless%20areas%20preserve.%20The%20DEIS%20names%20wild%20turkey%20and%20ruffed%20grouse%20among%20the%20game%20that%20needs%20complex%20forest%20structure%20with%20mast-producing%20trees,%20and%20notes%20sage%20grouse%20show%20strong%20site%20fidelity%20that%20limits%20how%20far%20they%20can%20adapt%20when%20habitat%20changes.%20Opening%20roadless%20areas%20to%20road%20construction%20and%20timber%20harvest%20degrades%20that%20structure.%20The%20agency%20has%20not%20explained%20how%20it%20will%20protect%20these%20upland%20species%20once%20that%20protection%20is%20removed,%20and%20I%20ask%20it%20to%20do%20so%20on%20the%20record.%0A%0AThe%20agency's%20own%20invitation%20on%20reliance%20interests%20goes%20unanswered%20in%20its%20economic%20work.%20The%20proposal%20solicits%20%22any%20reliance%20interests%20in%20the%20current%20rule%20that%20could%20be%20affected%20by%20this%20proposal%22%20(91%20FR%2053830-31),%20and%20the%20Cost%20Benefit%20Analysis%20weighs%20none.%20My%20family's%20use%20of%20these%20lands,%20and%20the%20expectation%20that%20untouched%20nature%20would%20remain%20protected%20under%20a%20rule%20in%20place%20for%20more%20than%20two%20decades,%20is%20exactly%20the%20kind%20of%20reliance%20interest%20that%20matters%20here.%20Under%20the%20administrative%20law%20principles%20that%20govern%20agency%20reversals,%20a%20change%20of%20course%20requires%20genuine%20engagement%20with%20what%20people%20and%20businesses%20built%20around%20the%20prior%20policy.%20I%20ask%20that%20the%20agency%20identify%20and%20weigh%20the%20reliance%20interests%20described%20in%20the%20comments%20it%20receives,%20including%20this%20one.%0A%0AThe%20agency's%20fire%20analysis%20points%20away%20from%20its%20own%20conclusion.%20Human-caused%20ignition%20density%20is%2022.4%20fires%20per%20million%20acres%20per%20year%20on%20roaded%20National%20Forest%20System%20land%20against%203.0%20inside%20the%20affected%20roadless%20areas%20(DEIS%20Table%2021,%202014-2024),%20and%20the%20DEIS%20states%20that%20human-caused%20ignitions%20increase%20in%20abundance%20with%20proximity%20to%20roads.%20The%20effects%20analysis%20itself%20concedes%20that%20road%20access%20could%20increase%20the%20number%20and%20frequency%20of%20wildfires.%20The%20agency%20claims%20the%20rescission%20will%20reduce%20wildfire%20hazard,%20but%20its%20own%20data%20suggest%20road%20access%20moves%20the%20ignition%20rate%20sharply%20upward.%20The%20agency%20must%20quantify%20the%20expected%20increase%20in%20human-caused%20ignitions%20from%20new%20road%20access%20and%20weigh%20it%20against%20the%20claimed%20reduction%20in%20wildfire%20hazard%20before%20this%20rule%20can%20go%20forward.%0A%0AFinally,%20the%20agency%20has%20structured%20its%20analysis%20to%20avoid%20examining%20what%20will%20actually%20follow%20from%20rescission.%20The%20proposed%20rule%20concedes%20that%20subsequent%20land%20management%20plan%20amendments%20and%20revisions%20%22could%20increase%20the%20area%20where%20timber%20harvest%20and%20road%20construction%20would%20be%20allowed,%22%20declares%20changes%20to%20plans%20beyond%20the%20scope%20of%20the%20proposal,%20and%20then%20requests%20public%20comment%20on%20them%20(91%20FR%2053830).%20That%20is%20asking%20the%20public%20to%20assess%20consequences%20the%20agency%20has%20placed%20outside%20its%20own%20analysis.%20The%20foreseeable%20plan-amendment%20scenario,%20including%20the%20expansion%20of%20timber%20harvest%20area,%20is%20a%20direct%20and%20predictable%20result%20of%20this%20action%20and%20belongs%20inside%20it.%20The%20agency%20should%20analyse%20that%20scenario%20as%20part%20of%20this%20rulemaking,%20not%20defer%20it.%0A%0ASincerely,%0AChristina%20Nicolas%20%0ALouisville,%20KY

The Forest Service has been able to take a vital leadership role in balancing the multiple dimensions of its mission through the 2001 Roadless Area Conservation Rule which enables it to manage public lands for conservation as well as for other uses needed and desired by the public. New roads through areas with relatively intact ecological value will provide accelerated access for development, over-harvesting of timber, and speed the movement of invasive species through the landscape, all of which accelerate the collapse of biodiversity that threatens the health of ecosystems necessary to sustain life for all of us. The loss of the 2001 roadless rule and its replacement with a jigsaw puzzle of local regulations will inevitably increase the pace of this unravelling. Small local governments can’t possibly have the resources and the depth of knowledge that the Forest Service is able to bring to vital decisions about land management, and the result will be that rather than coherent ecoregion-level management, one jurisdiction will create harms that negatively impact other jurisdictions nearby. I urge you NOT to change the 2001 Roadless Conservation Rule.