Read the comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Camping, rafting, and backpacking throughout the West has been part of my entire life. I rely on these places for solitude and the chance to connect with nature, and the proposed rescission of the 2001 Roadless Area Conservation Rule threatens both. I oppose it. The agency's own record undermines the wildfire rationale at the center of this proposal. 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 finding sits in the same document being used to justify opening these areas. The agency must explain how it can cite wildfire management as a reason for rescission while its own analysis documents that road access drives ignition rates upward. I ask that the agency explain why this proposal departs from those prior findings and how it reconciles the rescission with its own conclusions about ignition risk. The ignition data makes the contradiction more precise, not less. The DEIS reports that "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." A ratio that wide is not a rounding error. The places I have spent my life traveling through, camping and backpacking in the backcountry of the West, are precisely the kind of low-ignition environments this data describes. The agency has not explained how new road access into these areas would produce a net improvement in fire conditions. It must quantify the expected increase in human-caused ignitions from new road access and weigh that number honestly against any claimed reduction in wildfire hazard. Access to clean water should be a basic human right. Adding roadways to America's already over-taxed watersheds will do irreparable harm, and the agency's own analysis does not contradict that concern. The DEIS acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The watersheds fed by these roadless areas supply drinking water to millions of people. Opening them to road construction is not a reversible experiment. The agency should explain what safeguards, if any, it has analyzed that would prevent the kind of sediment loading its own documents describe, and it should respond to the water quality implications of this rescission. The regulatory flexibility certification in this rulemaking does not hold up. "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 no-impact conclusion is reached by spreading projected losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas. Some of those firms may lose these receipts entirely. Spreading the damage thinly across a national average does not make it disappear for the businesses actually exposed. The agency should withdraw the certification and assess the impact on the specific small entities operating inside the potentially affected roadless areas. Finally, the agency has not fulfilled its own invitation. "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." This comment is one such interest. I have organized my outdoor life around the existence of these protected areas. Under established administrative law, an agency reversing a longstanding policy must assess the reliance interests its prior rule created, not merely ask for them and then set them aside. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Kate Lips Salt Lake City, UT

To the USDA Roadless Rule Team: As a Coloradan, and a wildlife enthusiast, I believe the 2001 rule is the single most important land management instrument and the threat of its removal is not only catastrophic but infuriating. Every year, I take a fall trip to explore these beautiful mountains and every year I am left with wonder. Seeing new wildlife, a new sunset, a new plant, a riverbed - it never ceases to amaze me. The protection of these ecosystems are imperative for us, but also for all. Being able to backpack through these undisturbed mountains and connect with other life is one of the few things that bring me joy and peace in such a hectic world. Roads end that possibility. Regarding the Mount Antero in the Pike & San Isabel NFs- Alpine and Subalpine Climate Refugia Connectivity — The area spans from 13,600 feet to 14,276 feet across multiple subalpine and alpine ecosystem types—Rocky Mountain subalpine spruce-fir forest, alpine tundra, and bristlecone pine woodland—creating an intact elevational gradient that allows species to shift their ranges as climate conditions change. This vertical connectivity is critical as warming temperatures push suitable habitat upslope; species dependent on cool conditions can only persist if they can move continuously to higher elevations without fragmentation. Road construction fragments this gradient by creating edge effects, altering microclimate through canopy removal, and introducing invasive species along disturbed corridors, which would trap populations in lower-elevation refugia that are becoming increasingly unsuitable. DEIS Narrative Exceeds the 150-Page Statutory Limit With No Extraordinary-Complexity Determination on the Record The Draft EIS exceeds the statutory page limit and contains no determination authorizing it to do so. Volume I of the Draft EIS is 333 pages. Its narrative text runs from the Introduction at page 9 through page 248. References Cited occupies pages 249 through 285, and the List of Appendices and Appendices 1 through 5 occupy pages 286 through 333. Excluding citations and appendices, as the statute directs, the environmental impact statement is therefore approximately 240 pages long. The applicable limit is 150 pages. 42 U.S.C. 4336a, enacted by the Fiscal Responsibility Act of 2023, limits an environmental impact statement to 150 pages excluding citations and appendices, and permits 300 pages only where the proposed agency action is of extraordinary complexity. USDA's NEPA procedures implement the same limits at 7 CFR 1b.7(a) and (i). The Draft EIS expressly adopts those procedures, stating at page 9 that the Forest Service "has prepared this draft environmental impact statement (EIS) in compliance with the National Environmental Policy Act (NEPA) and other relevant laws and regulations," and that "all references to 7 CFR 1b within this document refer to the interim rule." The document therefore exceeds the 150-page limit by approximately 90 pages. The only lawful basis for an environmental impact statement of this length is a determination that the proposed action is of extraordinary complexity. Volume I contains no such determination. The phrases "extraordinary complexity," "page limit," and "Fiscal Responsibility Act" do not appear anywhere in the document, and 42 U.S.C. 4336a is cited nowhere in it. The Draft EIS asserts compliance with "other relevant laws and regulations" while exceeding the one quantitative constraint those laws place on the document itself, and without invoking the exception that would authorize the excess. This is not a matter of formatting. The page limit operates together with 7 CFR 1b.7(i), which directs that issues not of a substantive nature receive the briefest possible discussion. A ceiling of 150 pages applied to a rescission affecting approximately 44.7 million acres of National Forest System lands compels the agency to compress its effects analysis, and the extent of that compression depends directly on which ceiling the responsible official was working to. A document written to 150 pages must omit substantially more analysis than one written to 300. The public reading this Draft EIS cannot tell which constraint shaped it, because the document never says - and the difference is roughly 90 pages of effects analysis across 44.7 million acres. I request that the responsible official make and document the extraordinary-complexity determination required by 42 U.S.C. 4336a and 7 CFR 1b.7(a) as the predicate for a Final EIS exceeding 150 pages, or, if no such determination is made, that the Final EIS text comply with the 150-page limit. Under 7 CFR 1b.7(f)(3), the response to this comment should cite where in the Final EIS or the supporting proposal record that determination is accounted for. A rule that has survived twenty-five years, multiple administrations, and repeated judicial review deserves more deference than this. CommentID: RLC-20261006-9WBQV3

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Backpacking and hiking through places like Pyramid in the Lake Tahoe Basin and the Paiute roadless area in Inyo National Forest to commune with nature, watch birds, and observe wildlife, I have come to understand what these landscapes hold. Rescinding the 2001 Roadless Area Conservation Rule would put that at risk, and the agency's own analysis does not support the step it is proposing to take. I am an avid backpacker and day hiker who lives in Northern California. I have travelled all over the United States to hike and backpack. The impact of roads and off road vehicles on wildlife, the land and the experience being in the “wilderness” is obvious and depressing. Bird watching is not incidental to why I go into roadless areas. It is a central reason. The agency's own record, drawing on research the DEIS cites, documents 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. California already holds 381 inventoried roadless areas totaling 4,389,760 acres, and the birds I go to find depend on the quiet and the unbroken canopy those areas provide. Opening that landscape to road-building does not simply alter the scenery. It restructures the acoustic and ecological conditions that determine whether those species stay or go. I ask the agency to explain, with specificity, how the benefits it claims from rescission can be weighed against documented declines in bird abundance and species presence that its own cited science predicts. The wildfire rationale the agency offers for this rescission conflicts directly with what its own record says. 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." The DEIS further reports human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that human-caused ignitions increase in abundance with proximity to roads. The agency must explain why its proposal departs from these findings, reconcile the rescission with the ignition data in DEIS Table 21, and quantify the expected increase in human-caused ignitions from new road access weighed against any claimed reduction in wildfire hazard. The regulatory flexibility certification also cannot stand as written. The agency certifies no significant impact on small entities while its own DEIS names outfitters, guides, and tour operators as affected, and its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading expenditure loss across every small firm in the sector nationally rather than examining the guides and outfitters holding permits in the specific affected areas. The agency concedes some firms may lose those receipts. It should withdraw the certification and assess impact on the small entities actually operating in and permitted for the potentially affected roadless areas. The Chugach National Forest in Alaska is the most roadless national forest in the entire system. Ninety-nine percent of it has never had a road built through it. It holds 40 inventoried roadless areas totaling 5,439,110 acres. The Copper River Delta within it hosts the largest concentration of shorebirds in the Western Hemisphere during spring migration, including western sandpiper in the millions. Bald eagles, trumpeter swans, brown bear, moose, and mountain goat depend on this landscape at a scale that exists nowhere else in the national forest system. The 2001 rule is the structural protection that has kept those conditions intact. A state-petition process substituted for a national rule creates no guarantee that protection continues, and the agency's own record does not model what happens to that ecosystem if the rule falls. Finally, the proposal itself 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. My years of hiking, birding, and backpacking in California's roadless areas, and my expectation that federal policy would continue to protect them, are exactly the kind of reliance interests the agency invited and then declined to assess. The agency must identify and weigh those interests as part of this proceeding, including what this comment represents. Sincerely, Kristen Sorensen Petaluma, CA

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule (the Roadless Rule). I am a resident of Western North Carolina (WNC) where we are privileged to have many rare and wonderful species of plants and animals and pristine natural areas. The rescission of the Roadless Rule would negatively impact humans, plants, and animals in WNC. The Pisgah and Nantahala National Forests are home to many unique and sensitive species of plants and animals. The EPA reports that a preliminary biological assessment found the rescission of the Roadless Rule is likely to adversely affect 327 ESA-listed species and 71 designated critical habitats. One item this administration is championing as a positive reason to rescind the Roadless Rule is mitigation of wildfires. However, findings contradict the need for more roads to mitigate a perceived wildfire threat. The Purpose and Need argues that the 2001 Roadless Rule limited vegetation management and contributed to forest-health problems, but the agency's own Fire and Fuels Management chapter cites research finding that the Roadless Rule did not meaningfully constrain hazardous fuel treatment activities when measured as a share of forested land treated. The document's own cited evidence contradicts the central justification offered for rescinding the rule. The agency’s findings showed, “the 2001 Roadless Rule did not meaningfully constrain hazardous fuel treatment activities when considering the number and area of treatments” (Hazardous Fuel Reduction). In closing, for the reasons I have discussed, fully or partially rescinding the Roadless Area Conservation Rule would not benefit humans by reducing wildfires and would negatively affect plants and animals important to Western North Carolina. Thank you for your time. A Citizen of Watauga County, North Carolina

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The rescission of the Roadless Area Conservation Rule is, as far as I can tell, purely about removing regulatory burden. It does not promise road development. It does not promise logging. It simply strips away protection from some of the last remaining old growth forestland in the world, for no reason the agency has made plain. This is old growth. It takes centuries to even approach that designation. Reforestation efforts across the world today pale in comparison to what true old growth forest represents. If roads go in and that land is destroyed, nothing like it may never be able to grace the earth again. The Forest Service held more than 600 public meetings and took 1.6 million public comments to put this rule in place. To undo something so substantial without a single comparable public process is, to me, a mistake. I ask that the agency explain what process it believes substitutes for that record of public participation, and why rescission of a rule built on 1.6 million comments requires none of its own. On water, the agency's own data shows that 24 million Americans drink water that originates in these roadless areas. Roads are known to cause contamination in the areas where they are built. The agency's own analysis confirms this directly, finding that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Rescinding this rule opens those watersheds to exactly that kind of harm, affecting the drinking water of millions of Americans with little to no real benefit. I ask the agency to explain on the record what specific, quantified benefit justifies that risk to public water supplies. On wildfire, the proposal invokes forest health and fuels management as justification for rescission. The agency's own record says the opposite: "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 proposal offers no reconciliation with that finding. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence, and that it 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. On the state-by-state approach, the agency has already traveled this road and lost. The 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." Courts rejected that state-by-state substitute before. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified when the agency last tried to replace the national rule with state petitions. On statutory authority, the proposal argues the 2001 rule exceeded what Congress authorized. A federal appellate court already answered that question: "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 Tenth Circuit held the 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. The agency must explain on the record the basis for any position to the contrary. Finally, on administrative burden, the rule as written already contains exceptions, including for "the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency has not identified which specific burdens those exceptions fail to address. It must do so, with quantification, before rescission can stand as a proportionate response to any genuine operational difficulty. Future generations deserve to have this land, to experience the beauty the world has to offer, and we are discussing potentially opening the door to take that away.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The quiet found in backcountry areas is not available anywhere near roads and human development. I have hiked and camped in many such places, and I know that feeling of time slowing down, that grounded, peaceful quality that simply does not exist where roads are found. Each backcountry location is incredibly unique in so many ways, and each one we have matters for that variety, for the ecosystems found there, and for ourselves and our children's children to be able to experience. The proposal before the agency would put all of that at risk, and the agency's own record makes a poor case for doing so. Start with fire. The agency's own findings state that "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 proposal nevertheless justifies rescission partly on wildfire and fuels management grounds. The agency needs to explain, in plain terms, why this proposal departs from its own prior findings on fire occurrence, and how it reconciles 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 economics do not hold up either. The record acknowledges 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." Those are small numbers to set against significant permanent losses. 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 ranging from -$92 million to +$199 million. That range does not establish a net benefit. Meanwhile, the road system the agency would expand already carries a $6.9 billion maintenance backlog. How does an action whose own analysis cannot demonstrate a net positive outcome justify enlarging that liability? The agency has also been down this road before. The record quotes the agency itself expressing dissatisfaction with the Roadless Rule and rejecting its "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. That dissatisfaction led to a state-by-state replacement, and the Ninth Circuit struck it down. The proposal moves in the same direction again. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and it must explain how this proposal avoids the specific legal deficiencies identified the last time it tried to substitute state processes for one national rule. Finally, the existing rule already accommodates a range of management needs. It "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The exceptions for public health and safety, existing mineral leases, and community wildfire protection are already in the text. The agency claims administrative burden justifies rescission, but it has not shown which specific burdens those exceptions fail to address. It should identify them, by category, and quantify them before going further. The places I am writing about are irreplaceable. That variety of ecosystems, that quiet, that slow-down feeling, once a road cuts through it, it does not come back. The agency has not made a factual, legal, or economic case sufficient to justify this rescission, and I urge it to withdraw it. Kristen Portland, Oregon

Clean water matters to me, my kids deserve these vast beautiful lands, and I want to know how my tax money is being spent before it goes to something like this. The agency's fire safety argument does not hold up under its own numbers. The document states, at the Fire Control section, that "With increased road access, initial attack success rates would be expected to increase." But no analysis isolates roads as the cause of any difference in outcomes. The document itself acknowledges that less-than-full suppression is used more often in roadless areas, which makes any direct comparison of initial attack success rates unreliable without controlling for suppression strategy. It also concedes that most new roads expected under rescission would be temporary timber spurs, not strategic fire roads. The agency needs to separate the effect of roads from suppression strategy in its initial attack comparison, and estimate how many fire-useful roads are actually expected given real funding limits. I want a clear answer to that specific question before this rule moves forward. The agency also cannot have it both ways on irreversible harm. The Scope of the Analysis section declares that "An irreversible or irretrievable commitment of resources will not be made by the rulemaking because none of the rulemaking alternatives propose specific actions," yet the same document discloses that rescission is likely to adversely affect 327 ESA-listed species and 71 critical habitats, and that permanent road construction and old-growth removal are reasonably foreseeable. Those are exactly the kinds of irreversible commitments the disclaimer purports to rule out. The Forest Service must reconcile that contradiction directly. This is a horrible priority when we need healthcare, affordable housing, food, and so many other essential services. Do you want kids to grow up without these vast beautiful lands? I don't. The agency should explain, on the record, why rescinding nationwide protections serves the public better than keeping them.

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Fishing lakes, rivers, creeks, and streams without roads cutting through the surrounding land is one of the few remaining privileges available to people willing to make the trek. That is not a small thing. The ecosystems and habitats that support the life in those waters only hold together because human intrusion has been limited. To continuously push the development of infrastructure where it is not needed will lead to the devastation of it all entirely. I hike and camp for the same reason: to experience wildlife as it is, to disconnect, to encounter nature without extreme human intrusion. A large majority of this country has already been developed for commercial, agricultural, and residential use. What remains unroaded and intact should stay that way. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule in full and ask the agency to answer the specific questions raised below. The agency justifies this proposal in part on wildfire and fuels management grounds, but its own record contradicts that justification. The agency found that "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." Opening more roadless acres to road construction under that finding is not a fire management strategy. I ask the agency to explain how the proposal departs from those prior findings and to reconcile the rescission with the ignition data in its own draft environmental impact statement, which the record shows reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is just as weak. The agency's own analysis shows 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." Against those marginal gains, 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. The agency cannot establish a net benefit from this action, yet it proposes to expand a road system already carrying a $6.9 billion maintenance backlog. The agency must explain, in plain terms, how that arithmetic supports rescission. The agency also argues that state-specific approaches can replace a single national rule. But the agency's own record acknowledges that it "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 last time the agency substituted local decision-making for the national rule, the Ninth Circuit found that approach legally deficient. The agency has not explained how this proposal avoids the same deficiencies, and it has not addressed its own prior finding that local decision-making can incrementally erode nationally significant roadless values. A clear answer to both points is required. Finally, the proposal argues that the 2001 rule exceeded the agency's statutory authority. That question has already been litigated. A federal appellate court reviewed the challenge to the rule and held, exercising jurisdiction under 28 U.S.C. Section 1291, that it would "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 Tenth Circuit found 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. The agency needs to state plainly what basis it has for a contrary position, given that a federal court has already ruled on this question. This land was meant to remain untouched and preserved. Preserving the national forests for their ecosystems and wildlife is just as important as any commercial use. The agency should answer each of these points in the final record before any action on this proposal is taken. Sincerely, Mary Landaberde Groveland, Florida

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Roadless areas are very important to me. I could speak to generally how they help create more diverse and wild landscapes everywhere not just in their vicinity. The United States actually still has wild places unlike many other countries. But I will speak to my specific experience within Deep Creek Roadless Area. I hike there for the last 10 years every year. I love how I can not hear vehicles. I would be heartbroken if this place did not exist or if it was destroyed. To even build a single road in this area I am sure would destroy a lot. The waters in the creek are so clean and the hot springs so delicately placed near the creek. All that would be polluted with run off if roads were built. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about Deep Creek (23,869 acres), San Bernardino National Forest, California. 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 photograph trees, and my work is part of the recreation economy this document weighs. The agency certifies no impact while the analysis beside it says otherwise: 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: Foreseeable plan amendments are placed beyond scope I photograph landscapes, and every frame depends on what the management plans allow next. The agency concedes where this leads and then declares it out of scope: The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). The agency is asking commenters to perform the analysis it declared out of scope. I ask that the agency analyse the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action. Issue 3: Reliance interests are invited and never assessed I photograph wildlife, and years of that work are built on these protections holding. That is a reliance interest, and the agency invited me to name 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. Issue 4: 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. 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, Katherine Bauer Corona Del Mar, California

I am a 57 year old Oregonian and CTO of a clearing broker-dealer. Like many of us, I care deeply about the public lands that comprise the American wilderness. I moved here from Texas over 15 years ago in large part due to the natural beauty and the wild outdoors, which are a direct result of our historic conservation and preservation of these spaces. National parks, national forests, state parks and forest, bureau of land management -- I spend as much time as possible in all of these places. They are the very heart and soul of America, and of The West, and we must protect them in every way. I just drove from Portland, OR to Eureka, CA down 101 with a brief stop in the wilderness along the Rogue River halfway between Powers and Agness on Forest Road 33. It is rough and slow going, as challenging and inconvenient as it is inspirational, breathtaking, life-affirming to see untouched wild spaces and vistas as stunning as crossing the Rogue River. Open any of this to development -- topple the first domino -- and complete destruction of our natural environs and wild spaces will proceed in what seems like a blink of an eye. Do this now, my yet-unborn grandchildren -- my kids are 21 -- will lose a birthright that has until now conveyed to all Americans, one of the most valuable and precious things we have. Please do not rescind the roadless rule. P.S. AI didn't write this, and I didn't ask for or receive any help from people or machines. Straight from my head and heart, filled with love and hope, with equal parts concern and conviction. Wilderness Acreage Figures at Page 195 Stated Without Any Citation The Draft Environmental Impact Statement states, at page 195 (Chapter 3, "Recreation Opportunities and Setting," Effects of Alternative 3 – Modified Rule, subsection "Wilderness"): "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure carries a citation. The sentence is unsourced on its face. The next citation in the subsection, Landres et al. (2015), is attached to a different proposition — the five qualities of wilderness character interpreted from Section 2(a) of the Wilderness Act — and supports nothing about acreage. Nothing in the surrounding text identifies where either number came from, and a reader cannot trace either figure from the text to any entry in the literature cited. These are the two figures by which the Draft EIS characterizes the resource whose treatment under this rulemaking it then analyzes, and they are stated as fact inside the effects analysis for the Modified Rule alternative rather than in an introductory or background passage. National Wilderness Preservation System acreage is not a fixed quantity; it changes with each congressional designation, so a figure stated without a source and without a date cannot be checked by anyone. NEPA requires a "detailed statement" under 42 U.S.C. § 4332(2)(C). The Department's own procedures define substantive information to include information that meaningfully informs "compliance with applicable laws, executive orders, and regulations" (7 CFR 1b.11(a)(53)), and provide for "[m]aking factual corrections" as a response to a substantive comment (7 CFR 1b.7(f)(2)(v)). A headline resource figure that the public cannot trace to any source is not a verifiable element of a detailed statement. The agency cannot answer this concern by citing the passage in which the figures appear, because that passage is the one lacking the source. I request that the Final EIS do one of two things: (1) identify the source of both the 111.9-million-acre National Wilderness Preservation System total and the 36.7-million-acre National Forest System subset, state the date to which each is current, and add that source to the literature cited; or (2) if no source supports the figures as stated, correct them. Under 7 CFR 1b.7(f)(3), the response should cite where in the Final EIS or the supporting proposal record the action taken is accounted for.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Mountain biking and camping with my family in the Mt. Hood National Forest is not an abstract interest. I ride the Forest Road 44 trails. My kids come with me. That is the ground this comment stands on, and it is the ground this proposal puts at risk. The agency's own data on road infrastructure should stop this proposal before it starts. The Forest Service is already billions of dollars behind on maintaining the roads it has. Building new roads into country that currently has none compounds a maintenance burden the agency has not come close to meeting. The sensible course is to focus resources on improving current infrastructure, not extending it into areas that are still intact. I ask that the agency explain on the record why adding new road miles is justified when the backlog on existing roads remains unaddressed. Roadless watersheds feed the water supply for an enormous number of Americans, and the Forest Service's own analysis acknowledges that roads and their associated facilities can produce the large majority of sediment from a timber operation. Clean water is the best legacy we can leave the next generation. I want my kids to inherit that, and I want the agency to answer directly whether the sediment risk from new road construction in these watersheds has been weighed against whatever timber or resource benefit is claimed. The regulatory flexibility certification in this proposal does not hold up against what the supporting documents actually say. "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 certification reaches its conclusion by distributing the projected expenditure loss across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. That is not an assessment; it is an average used to obscure a real impact. 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. The proposal also invites public comment on reliance interests and then does nothing with them. "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." Families who have organized their recreation around roadless protections, outfitters who have built permit-dependent businesses under the existing rule, and communities whose water comes from these watersheds have all relied on the 2001 rule across more than two decades. Soliciting those interests and then leaving them unweighed in the economic analysis is not a lawful change of course. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. On fire, the agency's own numbers argue against the proposal. "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. Opening these areas to road construction would move the ignition density inside them toward the much higher rate observed on roaded land. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard before this proposal can proceed. Finally, the proposal treats the most consequential downstream effects as outside its scope while simultaneously asking the public to comment on them. "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." Rescinding the rule without analyzing what plan amendments will follow is analyzing only half the action. The foreseeable plan-amendment scenario, including expanded timber harvest area, belongs inside this analysis, not deferred to a later process the public cannot yet reach. The Forest Road 44 trails, the watershed those forests feed, and the country I want my children to know the way I know it are what is actually at stake. The 2001 rule should stand. Sincerely, Emily Martin Hood River, Oregon

I oppose any blanket rescission of protective regulations of the areas currently protected by roadless area regulations. Any modification or rescission of the current protective regulations should be narrowly tailored to apply only to particular areas where changes in roadless area protection are needed.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Green Mountains of Vermont and the White Mountains of New Hampshire are where I find exercise, tranquility, and connection to nature and the hiking community. I go there often, and what I find in those places, the wildness, the quiet, the beauty that belongs to all people, is exactly what this proposal would put at risk. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be entered into the docket record. Vermont holds 6 inventoried roadless areas totaling 25,096 acres. Those acres represent something that cannot be rebuilt once it is paved over. Public land should be managed for all people and protected so that the wild and beautiful spaces it contains remain available for everyone to enjoy. Rescinding the rule moves in the opposite direction, converting a national protection into a state-by-state patchwork where those spaces are only as safe as the next administrative decision. I ask that the agency address directly, in its final analysis, how rescission serves the public interest in retaining these spaces in their current condition. The agency's own fire data undercuts the case for opening these areas to road construction. The DEIS states that "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." These numbers do not support the suggestion that new roads reduce fire risk. They suggest the opposite. I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that figure honestly against whatever wildfire hazard reduction the proposal claims. The fiscal argument for this rescission is equally hard to square with reality. We already struggle to maintain the roads and infrastructure we have, and money should go into improving those rather than paving over nature. The agency is $6.9 billion behind on maintaining the roads it already operates, on a road budget of about $73 million a year. Building new roads into country that currently has none, under those conditions, is not a maintenance solution. It creates a new liability. The agency should explain, plainly and specifically, how it intends to fund the long-term upkeep of any roads built in areas currently protected by this rule. The regulatory flexibility analysis does not survive scrutiny. "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." That conclusion is reached by spreading losses across every small firm in the sector nationally, rather than looking at the guides and outfitters who actually hold permits in the affected areas. The Eastern region, which includes Vermont, has 286 municipal water intakes sitting in watersheds that contain affected roadless areas, and the communities and businesses that depend on those watersheds deserve an honest local accounting, not a national average. The agency should withdraw the no-impact certification and assess the actual small entities operating in these specific areas. The alternatives analysis is compromised at its foundation. "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 statement written to mandate deregulation cannot produce a genuine comparison of alternatives. NEPA requires that comparison, and framing the purpose around executive orders rather than forest conditions forecloses it before the analysis begins. The agency should restate the purpose and need in terms grounded in actual resource conditions and carry at least one genuinely protective alternative through a full effects analysis. Finally, the proposal invites reliance interests and then ignores them. "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." This comment is exactly such an interest. The 2001 rule has shaped how hikers, outfitters, water utilities, and communities have planned and invested for years. An agency changing course must assess those interests, not merely invite them. The agency should identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further.

FS-2025-0001-223869 Special Areas: Roadless Area Conservation I live in Salt Lake City, Utah. I often recreate on public land in Utah, Idaho, and Nevada. And very much appreciate these Public Lands. And the U.S. Forest Service personnel that are responsible for stewarding the Multiple-Use Sustained-Yield Act of 1960. That said, there are some reasonable arguments that can be made to review the 2001 Roadless Area Conservation Rule, and how it is applied. However, Spencer Cox, the governor of Utah, (the state in which I reside), has already said "Utahns love our forests, and loving these places means taking care of them.” He went on to say, "the Roadless Rule has tied the hands of local land managers with a one-size-fits-all federal policy." Unfortunately, the Governor used the phrase "Utahns love our forests", which implies that the federal forest lands in Utah are "our forests." These forests belong to all inhabitants of the UNITED STATES of AMERICA. I capitalized this to emphasis that public lands SHOULD be managed in a coordinated way that promulgates the will of all Americans. Individual state management can easily be influenced by the will of local politics. And bent to serve the will of local politicians and influential campaign donors. This often trends counter to what a significant percentage of the people of the U.S.A. deem to be productive. For these reasons, I am AGAINST a Cart-Blanc rescinding of the 2001 Roadless Area Conservation Rule. A rule that was formulated over numerous years of discussion and hundreds of public meeting. Overall, the current Administration has shown a negative bias toward environmental protections. And any broad based discussions that would favor global and local actions to slow down the harmful impacts of human activities.

I am heavily against rescinding this rule. The preservation of ancient forests is an important and integral part of ensuring that the world does not experience further ecological decline. It is all to easy to think that such actions can be reversed, but the clearing of ancient growth forests for road construction can damage what will take centuries of undisturbed maintenance to repair. As such, this is a case where an ounce of prevention is worth several pounds of cure. The proposal makes reference to "overgrown and fuel-loaded national forests," but that is precisely the reason the rule was established in the first place. Without a proper blanket regulatory prohibition, it can be all to easy for these irreplaceable features of our country to be destroyed, with no way to get them back without centuries of dedicated time investment.

(Note: This comment has been submitted as part of the document entitled "20261006_McNamara_FS-2025-0001-223869_Opposition.pdf". It has been submitted as a separate comment here as well for additional documentation purposes.) As a Colorado resident, I oppose the proposal to either partially or fully rescind the Roadless Area Conservation Rule. This proposal claims: “there is a need to increase local management flexibility and, where necessary, allow for active management to respond to changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface.” Per the current code of regulations (as of Oct 6, 2026) in Title 36 Part 294, roads and temporary roads can already be constructed for a number of exceptions including, but not limited to: a) a road being needed pursuant to reserved or outstanding rights (such as existing mining claims), b) a temporary road being needed to protect public health and safety in cases of imminent threat of flood, fire, or other catastrophic event that, without intervention, would cause the loss of life or property, and c) a temporary road is needed to facilitate tree cutting, sale, or removal within the first one-half mile of the community protection zone to reduce the wildfire hazard to an at-risk community or municipal water supply system. There are plenty of provision in the 2001 Roadless Rule to allow for active management of roadless land to mitigate wildfire and natural disaster risk and respond to changing and localized conditions. Fully or partially rescinding the existing roadless rule is unnecessary to mitigate wildfire and community safety hazards at the wildland-urban interface. Additionally, the rationale for this proposal states: “The Secretary of Agriculture has broad authority under statutes such as the Organic Administration Act of 1897 and the Multiple-Use Sustained-Yield Act of 1960 to manage the National Forest System for a variety of uses. Just as the establishment of the 2001 Roadless Rule was discretionary, this proposed rule is an exercise of discretion to determine the most appropriate process for balancing competing values and uses in inventoried roadless areas within that legal framework.” The Multiple-Use Sustained-Yield Act of 1960 (MUSYA) provides the Forest Service authority to manage national forest and grasslands ‘‘for outdoor recreation, range, timber, watershed, and wildlife and fish purposes.’’ The National Forest Management Act of 1976 (NFMA) reaffirmed multiple-use and sustained-yield as the guiding principles for land management planning of National Forest System lands (16 U.S.C. 1600, 1604). In defining ‘‘multiple use,’’ the MUSYA clearly provides that under multiple-use management some land will be used for less than all of the possible resource uses of the national forests and grasslands. The Roadless Area Conservation rule, currently allows a multitude of activities including motorized uses, grazing, and oil and gas development that does not require new roads to continue in inventoried roadless areas. The National Forest System contains an extensive system of existing roads; the current roadless rule does not close or otherwise block access to any of those roads. Under the existing roadless rule, management actions that do not require the construction of new roads are allowed, including activities such as timber harvesting for clearly defined, limited purposes, development of valid claims of locatable minerals, grazing of livestock, and off-highway vehicle use where specifically permitted. Existing classified roads in inventoried roadless areas may be maintained and used for these and other activities as well. Forest health treatments for the purposes of improving threatened, endangered, proposed, or sensitive species habitat or maintaining or restoring the characteristics of ecosystem composition and structure, such as reducing the risk of uncharacteristic wildfire effects, are also already allowed under the current rule where access can be gained through existing roads, by equipment not requiring roads, or under the exceptions started above.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The public lands belong to all of us, and I want this pristine nature to remain as is. The proposed rescission of the 2001 Roadless Area Conservation Rule moves in exactly the opposite direction, and the environmental review supporting it is legally and analytically deficient in ways the agency must address before proceeding. The most fundamental problem is that the entire analysis was structured to eliminate protective outcomes before they could be considered. Alternatives with more protection were dismissed as not responsive to 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." NEPA does not permit an agency to write its purpose as deregulation and then discard alternatives because they protect too much. The comparison NEPA requires cannot happen when the thumb is on the scale from the first sentence. I ask that the agency restate the purpose and need in terms of actual forest conditions and analyze at least one fully protective alternative on its merits. The wildfire rationale the agency has used in public discussion does not hold up against the agency's own numbers, and it is not even the stated legal basis for the action. The purpose and need is to reduce regulatory burden and return decisionmaking to local officials. Overlap with the wildland-urban interface as defined by HFRA is 9.8 million acres, 24 percent of the affected area, and the DEIS says the benefits of added fuel-management access "would likely be modest and localized." The agency itself constructed a WUI-targeted alternative that would have addressed fire concerns without eliminating protections across the entire inventoried roadless system, and then rejected it. Nationwide rescission is a far broader instrument than the fire problem, even as the agency describes it, could justify. Why was the WUI-targeted alternative the agency built discarded in favor of eliminating the rule entirely? The agency's treatment of the rule's exception provisions compounds these problems. The 2001 rule's exceptions were expected to be infrequent by design; their infrequent use is now offered as evidence of failure, in a document that concedes "the rule's intent for infrequent use." A safety valve that operates as designed is not broken. Citing its own intended operation as a reason to dismantle the underlying rule is circular, and the agency cannot use that reasoning to meet its burden of reasoned decision-making. The agency should publish the counts of exception requests, approvals, denials and processing times so the public and reviewing courts can evaluate whether any genuine operational problem exists. Taken together, these defects describe a process that began with a conclusion and worked backward. The deregulatory purpose foreclosed protective alternatives. The fire rationale is simultaneously overstated and not the legal basis for the action. The exception record that might support a finding of failure has not been disclosed. None of this satisfies the agency's obligations under NEPA or the Administrative Procedure Act, and none of it gives the public a fair opportunity to comment on a record that actually supports the decision being made. I want this pristine nature to remain as is. The 2001 Roadless Area Conservation Rule has provided the framework for doing exactly that. Rescinding it without a lawful, complete environmental review is not a legitimate path forward. Sincerely, Mike Kennett, PA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Living in Arizona, I value the ability to hike in remote areas without roads. The Oracle Roadless Area, the Butterfly Roadless Area, the Santa Rita area, and really any roadless corner of the Coronado National Forest matters to me. These lands are national treasures, not a holding area for money making. I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The Coronado holds 23 inventoried roadless areas totaling 482,687 acres. Those areas, spanning the Santa Ritas, the Rincons, and the other sky island ranges, are the connective tissue between isolated mountain forests surrounded by hot desert. Jaguars have been documented crossing from Mexico through the Santa Ritas into the Rincon Mountains and beyond, using the roadless corridors between those ranges as the only pathways that make that movement viable. The Upper Rincon Roadless Area, the Santa Rita area at 6,078 acres, the Happy Valley area at 7,972 acres: these are not abstract inventory entries. They are the ground where that connectivity either holds or breaks. Opening them to new roads does not protect them. It fragments them. I ask the agency to explain on the record why it believes the rescission is consistent with its own documentation of these corridors as irreplaceable biological pathways. 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." The proposal cites wildfire management as a justification for rescission. That argument moves in the opposite direction from the agency's own findings. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask the agency to reconcile the rescission with those ignition figures and explain the departure from its prior findings. The proposal also rests on economic and employment grounds. 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." 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 -$92 million to +$199 million. It makes no sense at all to build new roads when the agency cannot even maintain the current roads. The existing maintenance backlog stands at $6.9 billion against a road budget of about $73 million a year. The agency must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already collapsing under that backlog. The agency's own record states: "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 proposal argues that state-specific approaches can replace the national rule. That argument has been tested. The Ninth Circuit found that local decision-making can incrementally reduce nationally significant roadless values, and the state-by-state replacement was rejected. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres, and across the Southwestern region 739 municipal water intakes sit in watersheds containing affected roadless areas. What happens to those values under a patchwork approach is not a hypothetical. The agency must explain how this proposal avoids the deficiencies the Ninth Circuit identified when the national rule was last replaced with a state-by-state approach. Finally, the agency's record states: "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 proposal argues that the 2001 rule exceeded statutory authority. The Tenth Circuit held that the 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. The agency owes a clear explanation of the legal basis for any position contrary to that holding, and it must provide one. Sincerely, Andrea C. Tucson, AZ

I strongly support leaving the 2001 Roadless Rule intact. The rule was put in place for a reason - to ensure standard enforcement across all wilderness areas in the national forest portfolio. The argument of decreasing bureaucracy by allowing local management is as bankrupt as the argument that each port authority establish tariffs locally. The national forests are called national for a reason - manage them with national standards (and is not tat what rules and regulations are all about...establishing and enforcing standards). The Roadless Rule has worked well for 25 years. Additionally, the rule...like every other federal regulation and rule...includes a exception request and approval process. The national forest service needs to use it.