Read the comments.

Dear Chief: As someone who regularly travels on foot through areas designated as roadless under the 2001 Rule, I am in a position to observe that what the Rule protects is materially different from adjacent managed lands, and the Department's proposed rescission warrants scrutiny against that observable difference. Sam Knob and Flat Laurel Creek have some of the favorite hiking trails for me and my family. When hiking to the summit at Sam Knob, the 360 degree view across this wilderness area is breath taking. This is one of those places where hikers pause and enjoy the view and take that special picture that they want to remember. If the Roadless rule is rescinded, the development of bulldozed roadbeds across this rugged wilderness would damage the fragile balance of native plants and animals as they exist today. My family is drawn to this area specifically because it does not have developed infrastructure criss crossing the land. Regarding the Sam Knob (addition) in the Pisgah National Forest, North Carolina: Rescission of the Roadless Rule is a federal action that may affect each of the 14 listed or proposed species documented in the Sam Knob (addition) IRA, Pisgah National Forest, by removing protections that currently prevent habitat-degrading road construction and development. Federal records document 14 listed or proposed species in the Sam Knob (addition) IRA, Pisgah National Forest. ESA Section 7 requires individual consultation for each species that a federal action may affect. For the Sam Knob (addition) IRA, Pisgah National Forest, the DEIS must demonstrate that the agency has initiated or completed ESA Section 7 consultation addressing all 14 listed or proposed species, with individual determinations of effect for each species. “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing van Dijk et al. 2025, 2025 (https://doi.org/10.1007/s10980-025-02100-5)” “Habitat fragmentation strongly reduced species richness of plants and animals across experiments. Across experiments, average loss was >20% after 1 year, >50% after 10 years, and is still increasing in the longest time series measured (more than two decades). We were struck by the persistence of degradation to biodiversity and ecosystem processes and by the increase in many of the effects over time. — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing Haddad et al. 2015, 2015 (https://doi.org/10.1126/sciadv.1500052)” I'm filing this comment because I think the rescission is wrong, and I want that on record. Please keep the Roadless Rule in place. All the best, CommentID: RLC-20261006-KJWAM0

Dear Secretary Rollins, I have relied on the protections in the 2001 Roadless Area Conservation Rule for years, enjoying the National Forest interior with the confidence that this land would stay as it is. The proposed rescission would not simply adjust a policy. It would change the basic character of public land that the outdoor recreation community depends on. I, my parents, grandparents and great grandparents have lived within a mile of this National Forest for over a hundred years, and I have personally run and hiked over a thousand miles on the trails of North Massanutten on both the Western and Eastern ridges of Fort Valley. The place I know from those miles looks the way it does because the Roadless Rule has held, and there is no other regulatory mechanism to hold that line if it is rescinded. Quiet and solitude are part of what makes this forest a place of rest and renewal, and road construction, along with the traffic it brings, would degrade that experience directly, apart from any ecological damage. Rescission would not open the forest to us, we already have the access we need. It would introduce disturbance into a place whose value depends on staying undeveloped. This is not just personal to me. It reflects real ecological and regulatory concerns that belong in the rulemaking record for the Northern Massanutten Inventoried Roadless Area of the George Washington National Forest, Virginia. The roadless condition is currently protecting a rare and vulnerable plant community, even as it already faces some pressure. Mudhole Bog, a Special Biological Area here, is recognized by the Virginia Division of Natural Heritage, which has recommended extending its protected boundary specifically to safeguard the groundwater recharge area that feeds the seep. Vehicle traffic and camping already occur at the gate where the Mudhole Gap road meets Forest Road 66, near that recharge area, at the limited scale the current closure allows. Removing the Roadless Rule's restrictions on new construction and reconstruction would let that access expand well beyond its current footprint, increasing pressure on a groundwater system the state has already flagged as needing more protection, not less. Road construction more broadly introduces sediment, alters hydrology and delivers contaminants to adjacent habitats, harms that follow directly from increased recreational road access. This area, along with the nearby Signal Knob Shale Barren, supports rare Central Appalachian plant communities that persist despite pressure from invasive species like Emerald Ash Borer, Hemlock Woolly Adelgid, Tree-of-Heaven, Japanese Stiltgrass and Garlic Mustard, and staying roadless prevents the disturbed corridors that invasive species use to establish and spread. A programmatic-level analysis cannot resolve these concerns. The DEIS needs to evaluate how increased recreational road access would affect the northern long-eared bat, a federally endangered species known to occur in Virginia forests, at the scale of this roadless area specifically, with enough detail to actually inform the decision. This is a site-specific concern, not a general one: a 2025 study in Landscape Ecology found that road traffic reduced breeding bird densities by an average of 25 percent within roughly 650 meters of a road, with the effect growing larger as traffic increased (https://doi.org/10.1007/s10980-025-02100-5). This is exactly the kind of impact a programmatic review misses. My family has cared for this land for over a hundred years, using it for quiet recreation without ever needing it developed further, and the rare plant communities that define it are still here because of that restraint. The rulemaking record does not offer an adequate justification for undoing it. The Department should decline to proceed and let this forest remain a place for quiet recreation, not further road construction. Most respectfully, John Lawrence

Dear Chief Tom Schultz: I am an avid hiker in Alabama. I know the joys of hiking where you cannot see, hear, smell, or feel the touch of “civilized man”. I also know the abrupt, jarring experience of suddenly coming upon a road - the trash, the sound of engines, the absence of wildlife at ease in their natural habitat. The facts show, from my understanding, that roadless areas are far less susceptible to wildfires so that federal argument is bogus. My hiking trips into the forest, where I restore my body, mind and soul, would be gone. I would lose that total seclusion that I crave, the sense that there is still somewhere I can go where I see our great country unspoiled by man. As an outdoor enthusiast who understands what it means to travel in country that has been kept outside the road system by regulatory protection rather than by geographic inaccessibility, I submit that the proposed rescission of the 2001 Rule would remove a protection whose absence would be felt concretely and irreversibly across the national forest landscape. Regarding the Cheaha A in the Talladega National Forest, Alabama: "Increases in fine sediments are known to change grain size distribution and consequently cause degradation of spawning grounds. The increase of fines clogs the pore space and can lead to 'sustained clogging,' since the turnover rate is markedly reduced or prevented even in the case of exceptional high flows. In such situations, washed out soil (e.g., from agricultural land use) or fines may lead to sedimentation of fines on coarse bed material and/or artificially placed gravel with consequent, negative impacts on embryo survival of gravel-spawning fish through suffocation." — Springer Nature — book chapter in Riverine Ecosystem Management, 2018 “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups. — Landscape Ecology (Springer Nature), 2025 (https://doi.org/10.1007/s10980-025-02100-5)” Monarch (Danaus plexippus), ranked G4 by NatureServe and federally listed (PT), is present in the Cheaha A IRA, Talladega National Forest, where it confronts 5.3 - Logging & wood harvesting at Moderate or 11-30% pop. decline severity across Restricted - small scope. The roadless character of Cheaha A currently prevents the infrastructure penetration that initiates 5.3 - Logging & wood harvesting. Rescission removes that barrier, allowing road construction to trigger the full cascade of impacts documented in NatureServe's threat assessment for Monarch. If the DEIS does not evaluate how rescission affects Monarch (Danaus plexippus, G4) in Cheaha A with respect to 5.3 - Logging & wood harvesting, the agency has failed to consider an important aspect of the problem — a standard basis for finding an EIS inadequate under NEPA. Let the roadless areas remain what they are. Thank you. CommentID: RLC-20260916-2SDMDU

To the Roadless Rule Rulemaking Team: As an outdoor enthusiast who has traversed national forest in multiple regions, I am filing these comments to urge the Department to conduct a more deliberate analysis of long-term public costs before rescinding a rule that has, for more than two decades, functioned as the primary regulatory safeguard for the nation's most significant remaining roadless forest landscape. My three children, my husband and I have spent countless years camping, hiking and enjoying this area. We not only call it home but we also learn and play here. My kids learned to backpack here; bulldozed roadbeds would end those trips. Regarding the Wilson Creek in the Pisgah National Forest, North Carolina: In the Wilson Creek Inventoried Roadless Area, Pisgah National Forest, Northern Pygmy Salamander (Desmognathus organi, G3,) faces documented threat from 5.3 - Logging & wood harvesting at Serious or 31-70% pop. decline severity across Restricted (11-30%) scope. The intact, unroaded condition of Wilson Creek is the functional mechanism that currently limits 5.3 - Logging & wood harvesting to its assessed severity and scope. Road construction removes this constraint and permits escalation. Failure to analyze 5.3 - Logging & wood harvesting impacts to Northern Pygmy Salamander (Desmognathus organi, G3,) in the Wilson Creek IRA renders the DEIS inadequate under NEPA. The administrative record must address this species-threat-area interaction or the analysis is arbitrary. "In 2001, the Roadless Area Conservation Rule prohibited road construction and timber harvest in 240,000 km² of inventoried roadless areas (IRAs) located on United States Department of Agriculture Forest Service lands. Many IRAs are among the most wild, undeveloped areas both in the nation and within their respective states. IRAs increase the size of—and reduce isolation between—protected areas, likely buffering them from external stressors. In some places, IRAs protect watersheds that deliver drinking water to hundreds of thousands of people." — Conservation Science and Practice (Wiley), 2020 “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups. — Landscape Ecology (Springer Nature), 2025 (https://doi.org/10.1007/s10980-025-02100-5)” The Forest Service should not rescind a rule that has governed inventoried roadless areas across administrations of both parties without a lawful and sufficient basis for doing so. Respectfully, Michelle Lyerly

Dear Secretary Rollins, As an avid hiker in roadless areas within Alabama, I realize how much we all need these untouched areas for their quiet beauty, changing seasons and admiration of nature. Your proposed removal of the Roadless Rule would substantially damage what I and many others in Alabama enjoy. I have hiked, camped and spent many enjoyable years in the Talladega National Forest and the Cheaha Wilderness. It would be devastating to see this area desecrated by repealing the Roadless Rule. The solitude and peacefulness of hiking to McDill Point and Hernandez Peak via the Pinhoti trail by myself, without another person and no roads was an experience I will never forget. Regarding the Cheaha B in the Talladega National Forest, Alabama: Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Rescinding the Roadless Rule would open the Cheaha B, Talladega National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. “Section 404 of the Clean Water Act (CWA) establishes a program to regulate the discharge of dredged or fill material into waters of the United States, including wetlands. Activities in waters of the United States regulated under this program include fill for development, water resource projects (such as dams and levees), infrastructure development (such as highways and airports) and mining projects. Section 404 requires a permit before dredged or fill material may be discharged into waters of the United States, unless the activity is exempt from Section 404 regulation (e.g., certain farming and forestry activities). The basic premise of the program is that no discharge of dredged or fill material may be permitted if: (1) a practicable alternative exists that is less damaging to the aquatic environment or (2) the nation's waters would be significantly degraded. — U.S. Environmental Protection Agency (https://www.epa.gov/cwa-404/permit-program-under-cwa-section-404)” “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups. — Landscape Ecology (Springer Nature), 2025 (https://doi.org/10.1007/s10980-025-02100-5)” “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups. — Landscape Ecology (Springer Nature), 2025 (https://doi.org/10.1007/s10980-025-02100-5)” I haven't found any viable science behind your decision to rescind the Roadless Rule repeal. But I have found substantial science to the contrary of your repeal. Respectfully, Don Coker

Dear Brooke L. Rollins, I write in opposition to the proposed rescission as a birder who has watched the federal scientific literature on road-density effects accumulate across two decades, and who finds that literature dispositive against rescission. Time spend in the habitat and witnessing bird and inspect species is of great joy but also sorrow. Knowing that if we do not protect these spaces, we rob future generations. During the pandemic, taking my kids hiking for outdoor learning gave us much needed reprieve from learning on screens. It was a way to connect to each other, the land and wildlife. Briscoe Creek Regarding the Briscoe in the Mendocino National Forest, California: Conservation status G2 reflects the vulnerability of Northwestern Pond Turtle (Actinemys marmorata) in the Briscoe Inventoried Roadless Area, Mendocino National Forest, where 7.2 - Dams & water management/use acts at Serious - moderate severity across Pervasive (71-100%) scope. Absent roads, Briscoe functions as a refuge where Northwestern Pond Turtle is buffered from 7.2 - Dams & water management/use. The roadless condition suppresses the access, fragmentation, and runoff pathways that convert this threat from potential to realized. If the DEIS does not evaluate how rescission affects Northwestern Pond Turtle (Actinemys marmorata, G2) in Briscoe with respect to 7.2 - Dams & water management/use, the agency has failed to consider an important aspect of the problem — a standard basis for finding an EIS inadequate under NEPA. "Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups." — Landscape Ecology (Springer Nature), 2025 “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups. — Landscape Ecology (Springer Nature), 2025 (https://doi.org/10.1007/s10980-025-02100-5)” Failure to Connect Species/Habitat Baseline to Rescission-Specific Impacts Analysis The species and critical habitat baseline in this DEIS is disconnected from any actual impacts analysis, which is a serious gap for a rulemaking that will determine road access across millions of acres of habitat. The document states that "the potentially affected environment provides habitat for more than 300 threatened, endangered, and proposed species" and lists 79 USFWS and 19 NMFS critical habitats, but nowhere connects these counts to how increased road construction, timber harvest, fragmentation, or sedimentation under the action alternatives would affect these species. Independent research confirms roads produce measurable habitat degradation extending up to 5 km from the roadbed, with cumulative effects on isolation and population viability; the DEIS does not engage this literature or explain why it is inapplicable here. Under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989), Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998), and APA 5 U.S.C. § 706(2)(A), I request species-specific or habitat-guild-level analysis linking projected road and harvest increases to fragmentation and habitat-loss effects before this rule is finalized. Rescission would not be a reasoned policy choice on the record presented; the Department should not finalize it. Respectfully, CommentID: RLC-20260908-OTV7WU

Dear Secretary Rollins and Chief Schultz: I write in opposition to the proposed rescission as a birder who has watched the federal scientific literature on road-density effects accumulate across two decades, and who finds that literature dispositive against rescission. Time spend in the habitat and witnessing bird and inspect species is of great joy but also sorrow. Knowing that if we do not protect these spaces, we rob future generations. During the pandemic, taking my kids hiking for outdoor learning gave us much needed reprieve from learning on screens. It was a way to connect to each other, the land and wildlife. Briscoe Creek Regarding the Briscoe in the Mendocino National Forest, California: 7.2 - Dams & water management/use drives Serious - moderate severity impacts across Pervasive (71-100%) scope for Northwestern Pond Turtle (Actinemys marmorata, G2, PT) in the Briscoe IRA, Mendocino National Forest. The intact, unroaded condition of Briscoe is the functional mechanism that currently limits 7.2 - Dams & water management/use to its assessed severity and scope. Road construction removes this constraint and permits escalation. Failure to analyze 7.2 - Dams & water management/use impacts to Northwestern Pond Turtle (Actinemys marmorata, G2, PT) in the Briscoe IRA renders the DEIS inadequate under NEPA. The administrative record must address this species-threat-area interaction or the analysis is arbitrary. "Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups." — Landscape Ecology (Springer Nature), 2025 “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups. — Landscape Ecology (Springer Nature), 2025 (https://doi.org/10.1007/s10980-025-02100-5)” Retain the Roadless Rule. With best wishes, CommentID: RLC-20260906-C7EB00

Dear Secretary: My children will read what happened here. I want the record to show this was contested. My childhood in Maryland was spent enjoying the nature of the Chesapeake Bay and the Appalachians on an annual camping trip but those mountains were so small compared to what I have experienced in California since moving here 15 years ago. I want to raise my daughter to appreciate the outdoors as much as I did - rafting, boating, hiking. Among many days in these forests, one has stayed with me. My daughter is only 3 but she already has her mom’s love of water and swimming and tossing rocks in the water on a recent trip. The Department is not being asked to weigh an abstract preference; it is being asked to weigh a concrete, demonstrated interest of the kind the Rule was enacted to protect. Regarding the North Fork American River in the Tahoe National Forest, California: Cold-Water Stream Integrity — The North Fork American River and its tributaries — Humbug Creek, Little and Big Granite Creeks, Palisade Creek, and Tadpole Creek — originate largely within this roadless area. Without road construction and its associated cut slopes the water quality will suffer. The persistence of Giant Sequoia in North Fork American River under current threat levels presumes continued roadless conditions. Road construction fundamentally alters this baseline, converting the landscape from one that constrains 7.1.1 - Increase in fire frequency/intensity to one that accelerates it. A programmatic analysis is insufficient. The DEIS must evaluate 7.1.1 - Increase in fire frequency/intensity impacts to Giant Sequoia (Sequoiadendron giganteum, G3) at the scale of the North Fork American River Inventoried Roadless Area, Tahoe National Forest, with specificity adequate to inform the decision. "Increases in fine sediments are known to change grain size distribution and consequently cause degradation of spawning grounds. The increase of fines clogs the pore space and can lead to 'sustained clogging,' since the turnover rate is markedly reduced or prevented even in the case of exceptional high flows. In such situations, washed out soil (e.g., from agricultural land use) or fines may lead to sedimentation of fines on coarse bed material and/or artificially placed gravel with consequent, negative impacts on embryo survival of gravel-spawning fish through suffocation." — Springer Nature — book chapter in Riverine Ecosystem Management, 2018 “Stream fragmentation is a leading threat to freshwater fish diversity and is often caused by the installation of impassable culverts at road–stream crossings. In the United States alone, millions of culverts contribute to this fragmentation. Emerging research suggests that smaller barriers, such as culverts, can have cumulative effects on riverine fragmentation that are comparable to those of large dams. — River Research and Applications (Wiley), 2026 (https://doi.org/10.1002/rra.70075)” “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups. — Landscape Ecology (Springer Nature), 2025 (https://doi.org/10.1007/s10980-025-02100-5)” This is a formal request that the Secretary allow the 2001 Roadless Area Conservation Rule to remain in effect. Sincerely, CommentID: RLC-20260823-TBXLO4

To the Roadless Rule Rulemaking Docket: For an outdoor enthusiast, roadless public land is not a luxury — it's the version of public land that delivers what public land is for. Regarding the Woodford 09086 in the Green Mountain and Finger Lakes National Forests, Vermont: Population-level impacts of not assessed severity across not assessed scope are documented for Northern Myotis (Myotis septentrionalis, G2, E) in the Woodford 09086 IRA, Green Mountain and Finger Lakes National Forests, driven by 6.1 - Recreational activities. The roadless character of Woodford 09086 currently prevents the infrastructure penetration that initiates 6.1 - Recreational activities. Rescission removes that barrier, allowing road construction to trigger the full cascade of impacts documented in NatureServe's threat assessment for Northern Myotis. The agency cannot satisfy its analytical obligations with a national-level discussion of roadless values. The DEIS must address 6.1 - Recreational activities as it affects Northern Myotis (Myotis septentrionalis) specifically within the Woodford 09086 IRA, Green Mountain and Finger Lakes National Forests. "Grazing by domestic herbivores is the most widespread land use on the planet, and also a major global change driver in grasslands. We show that aridity partly explains the responses of biodiversity and multifunctionality to long-term livestock grazing. Grazing greatly reduced biodiversity and multifunctionality in steppes with higher aridity, while had no effects in steppes with relatively lower aridity. Long-term grazing had no effects in meadow steppes with relative lower aridity, but reduced biodiversity and multifunctionality in desert steppes with higher aridity." — Nature Communications, 2023 “The current national forest road system includes 380,000 miles of roads. The agency also has a road reconstruction and maintenance backlog of approximately $8.4 billion, and it receives only about 20 percent of the annual funding needed to maintain its road system up to safety and environmental standards. — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-james-furnish-statement-before-senate-20000726-stelprdb5137345.pdf)” “When the 2001 Rule was issued, the NFS road system was over 386,000 miles long. The FS argued that budget constraints, coupled with the size of the forest road system, prevented the agency from managing the road system to required safety and environmental standards. For example, in issuing the 2001 Rule, the FS indicated that there was an estimated $8.4 billion in deferred maintenance and reconstruction on NFS roads and that, in addition to the 2001 Rule, it sought additional measures to control the transportation share of its budget. — Congressional Research Service, 2020 (https://www.congress.gov/crs_external_products/R/PDF/R46504/R46504.2.pdf)” “Roads cause habitat loss and fragmentation not only through their physical occupation, but also through traffic noise. The results showed that the habitat loss due to noise effect zone is dramatically higher than that due to road land-take only (35% versus 1.04% of the total area). We conclude that, although the roads are breaking apart the patches by land-take, road noise not only dissects habitat patches but takes much larger proportions of or even functionally eliminates entire patches. — Hossein Madadi | Hossein Moradi | Alireza Soffianian | Abdolrassoul Salmanmahiny | Josef Senn | Davide Geneletti, 2017 · Environmental Impact Assessment Review (https://doi.org/10.1016/j.eiar.2017.05.003)” “Construction of roads, utility corridors and other human infrastructure kills any sessile or slow-moving animal and all vegetation in the path of the feature. Roads and other linear infrastructure negatively impact wildlife through increased mortality, decreased habitat amount and quality, changing species movement patterns, and fragmentation of populations into smaller subpopulations, which are more vulnerable to local extinction. — Trombulak, S. C., and C. A. Frissell, 2000 · Conservation Biology (https://doi.org/10.1046/j.1523-1739.2000.99084.x)” “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. — René E. van Dijk, Toine Morel, Karen Zwerver, Paul van Els, Ruud P. B. Foppen, 2025 · Landscape Ecology (https://doi.org/10.1007/s10980-025-02100-5)” Nothing in the proposal persuades me that the Rule has failed to serve the purposes for which it was adopted. Sincerely, Dr. Becky Phillips