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I am an Alaska resident with a strong interest in the long-term stewardship of our public lands and natural resources. The Tongass National Forest is an important part of Alaska's environmental, cultural, and economic landscape. I believe it is essential to protect Alaska’s old growth forests, fish and wildlife habitat, and watershed health for the benefit of future generations. These resources are part of what makes Alaska unique, supporting our communities, economy, and way of life while providing opportunities for residents and visitors alike. By safeguarding these landscapes today, we can ensure that healthy forests, productive fisheries, abundant wildlife, and clean water remain available for the next hundred years and beyond. The Tongass contains some of the most extensive old-growth forests remaining in the United States and is widely recognized for its ability to store large amounts of carbon in its trees, soils, and forest ecosystems. These forests developed over centuries and provide ecological functions that are difficult to replace once disturbed. In addition to carbon storage, old-growth forests support biodiversity, watershed health, and habitat for a wide range of fish and wildlife species. Because the Tongass is one of the largest remaining temperate rainforests in the world and is often described as the nation's largest forest carbon sink, management decisions affecting these forests can have implications for both regional ecosystems and long-term carbon storage. The Tongass also provides critical habitat for salmon, bears, Sitka black-tailed deer, bald eagles, and numerous other species. Its extensive network of undeveloped streams and rivers supports some of the most productive salmon runs in the world, which in turn sustain commercial, recreational, and subsistence fisheries throughout Southeast Alaska. Healthy salmon populations are a cornerstone of the broader ecosystem, providing a food source for bears, eagles, and other wildlife. Large, intact landscapes help maintain these ecosystems by minimizing habitat fragmentation and preserving the stream conditions that fish and wildlife depend upon. Beyond their ecological value, these resources support industries and traditions that are central to life in Southeast Alaska. Commercial fishing, tourism, hunting, wildlife viewing, and subsistence activities all benefit from healthy fish and wildlife populations, making the long-term health of the Tongass important to both local communities and the regional economy. Additionally, the U.S. Forest Service already faces a multibillion dollar road maintenance backlog, and constructing additional roads would create new long-term maintenance, repair, and replacement obligations. Fiscal concerns over expanding an already extensive road network were a key factor in the development of the 2001 Roadless Rule, which recognized that the agency was struggling to adequately maintain existing infrastructure. In Alaska, where road construction and maintenance is particularly costly due to remote locations and challenging environmental conditions, expanding the road system raises important questions about the long-term financial sustainability of additional road development. Protecting these lands today is an investment in Alaska’s future. By maintaining healthy old growth forests, clean watersheds, and thriving fish and wildlife habitat, we can ensure that the natural resources and landscapes that define Alaska continue to support our communities and enrich the lives of residents and visitors for generations to come.

I am in favor of no action option. Opening our remaining roadless areas will: + Destroy valuable wildlife habitat + Impact protected watersheds + Increase uncontrolled public access will lead to more forest fire starts from poorly supervised camping + Increase administrative costs of patrolling, garbage removal, etc. from an agency already hurting from budget stress + Increased costs of road construction and maintenance.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Road sediment is quantified and then set aside I paddle water that starts in this country, and clean, free-running rivers are the whole reason I go. What roads send into a watershed lands directly on people like me. The DEIS: skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." The number appears in the document; no projection of sediment delivery follows it. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. Issue 2: Twenty-four million people's drinking water is asserted away I paddle rivers that begin in these forests, and I am downstream of every decision made above them. That is why I raise what this proposal means for drinking water. Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired. The DEIS says forest plans address sources of public drinking water without identifying one enforceable provision. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. Issue 3: Unmaintained roads damage water, by the agency's own admission As a paddler I live with whatever a watershed sheds. A road nobody can afford to maintain fails into the river, and the agency admits as much in its own words. "Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance." The same document proposes adding road mileage against a maintenance shortfall it identifies as a cause of water quality damage. I ask that the agency reconcile the proposed increase in road mileage with the maintenance shortfall its own analysis identifies as a water quality cause. Issue 4: The agency cannot afford the roads it already has This is my money. Before the agency commits to building more, I want it to account for what it already cannot maintain. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring. The DEIS states that road mileage, deferred maintenance and management costs are likely to increase under the proposal. I ask that the agency name the funding source for new road construction and maintenance and state the projected change in the backlog. Issue 5: The agency's own accounting cannot say if this makes money or loses it I care how my tax money gets spent, and I expect an honest accounting before public assets are traded away. The agency's own analysis cannot provide one. The Cost Benefit Analysis: "the net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million (-$70 to $152 million discounted at 7 percent) and uses maximum potential costs and benefits that do not account for uncertainty." The cost column excludes the road construction ($80,000 to $100,000 per mile, roughly $500,000 per mile in Alaska), maintenance and fuel treatment costs the same document quantifies, and the upper bound assumes maximum potential harvest the analysis itself calls uncertain. An economically significant rule whose own analysis spans from a $92 million loss to a $199 million gain has not shown a benefit; the analysis was published in an agency file folder rather than on the docket, and the rule's claim that impacts "could exceed $100 million" (91 FR 53830) appears with no arithmetic anywhere, though every quantified annual line item is under $22 million. I ask that the agency place the Cost Benefit Analysis on the docket, restate the net present value with its own quantified road and fuels costs included in the cost column, and show the arithmetic behind the statement that impacts could exceed $100 million. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Amy Ball

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The peace I find away from human development, and the chance to show my son the beauty of nature, is exactly what would be lost if this administration guts the 2001 Roadless Area Conservation Rule. I am filing this comment in opposition to the proposed rescission under Docket FS-2025-0001. I take it on faith that so-called leaders are supposed to work for the public, not corporate interests. That faith has been tested here. The agency held more than 600 public meetings and took 1.6 million comments to write the rule it now proposes to undo. It has held none to undo it. I cannot imagine many support this initiative to build roads in our last remaining wild places besides those who profit from building these roads and logging these rare and sacred spaces. I ask that the agency value the voices of the people, not the voices of consumption and profit. The fiscal logic of this proposal fails on its face. The agency's own data show that "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." It makes no sense to build more roads when we already cannot maintain the ones we have. The DEIS states that road mileage, deferred maintenance and management costs are likely to increase under the proposal. I ask the agency to name the funding source for new road construction and maintenance and to state the projected change in that backlog. Clean water is life. More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas, and the agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. We must protect the very things that allow us to live on this earth. The agency has not explained how opening these last unroaded forests to road construction is consistent with protecting the water quality those watersheds provide. I expect a direct answer to that question in the final record. My son loves to hike and camp. Future generations deserve the same access to wilderness that past generations have enjoyed. Species besides humans deserve respect and dignity. Plants and animals deserve protection from human development. They are living beings, and their fate is bound up with these unroaded landscapes. The agency's economic certification ignores both of these realities. "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 regulatory flexibility analysis reaches its no-impact conclusion by spreading the expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas. The agency must withdraw that certification and assess the impact on the small entities actually operating in these roadless areas. Forests are our lungs. The agency's own fire record makes the case for keeping them intact. "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. The agency has not quantified the expected increase in human-caused ignitions that new road access would bring, nor has it weighed that increase against the claimed reduction in wildfire hazard. That gap must be filled before any final decision is made. Finally, "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. The expectation that these lands would remain unroaded has shaped how people like me think about what we can share with our children. An agency changing course must assess the reliance interests its prior policy created. I ask that the agency identify and weigh every reliance interest described in the comments it receives, including this one, before it proceeds further. Sincerely, Abbi Surles Bloomington, IN

I’m writing as a dad, a hunter, an angler, and someone who spends a lot of time on our public lands. I live in Helena, Montana, and these places are important to me and my family. I urge the U.S. Forest Service to keep the 2001 Roadless Rule in place. I value our public lands because they give my family and me places to hunt, fish, hike, camp, and simply get away from roads and development. Some of the best wildlife habitat and backcountry experiences we have left are in these roadless areas. The Roadless Rule doesn’t prevent hunting, fishing, grazing, recreation, habitat work, wildfire mitigation, or access to existing rights. What it does is provide some protection from building new roads into some of our most intact public lands. As a hunter and angler, I worry about what happens when we continue adding roads into these areas. Roads can fragment wildlife habitat, affect migration routes, impact streams and watersheds, and change the character of the backcountry. Once a road is built, it is very difficult to undo. The Forest Service already manages hundreds of thousands of miles of roads and has a huge backlog of road maintenance. I have a hard time understanding why we would take on even more long-term road construction and maintenance when the agency is already struggling to maintain the roads we have. More importantly, I want my kids—and eventually their kids—to have the same opportunity to hunt, fish, and experience wild public lands that I have had. I understand that forest management needs to change and that there are times when roads and active management make sense. I support responsible, locally informed management of our public lands. But removing protections from millions of acres of roadless country goes much further than that. These lands belong to all of us. Once we permanently change some of our last remaining intact backcountry, we don’t get it back. Please listen to the people who use and care for these lands. I respectfully ask the Forest Service to keep the 2001 Roadless Rule in place. As a dad, hunter, and angler, I want to leave these places better for the next generation—not more developed. Thank you for considering my comments.

My family has hiked and camped in the Superior National Forest in Minnesota for more than a decade, and the character of that landscape—its quiet, its intact ecosystems, its sense of true remoteness—exists today because of the protections established under the 2001 Roadless Area Conservation Rule. These areas are not theoretical policy abstractions; they are real places that Americans rely on for recreation, clean water, wildlife habitat, and climate stability. Removing national-level protections would jeopardize all of these values. Roadless areas are among the last remaining large, unfragmented tracts of public land in the country. Once roads are built, the ecological impacts are immediate and irreversible. Roads introduce noise pollution, fragment wildlife habitat, increase erosion, and open previously remote areas to human-caused disturbances. Research consistently shows that human-caused wildfires are far more likely to start near roads—up to four times more likely—meaning that roads do not reduce fire risk; they increase it. The claim that rescinding the rule will improve local flexibility ignores the fact that roadless areas are already functioning as natural buffers against wildfire ignition. These landscapes also serve as critical carbon vaults. Intact forests store carbon far more effectively than fragmented ones, making roadless areas an essential tool in mitigating climate change. In the Superior National Forest, these protections help safeguard one of the most important freshwater systems in the world. The forest is a foundational part of the Lake Superior watershed, and maintaining its roadless character helps ensure that Lake Superior—an irreplaceable resource for millions—remains clean. Economically, road construction and maintenance impose significant long-term costs on taxpayers. The Roadless Rule prevents the creation of new financial liabilities for the federal government while preserving the ecological and recreational benefits that already exist. The idea that rescinding the rule will “reduce regulatory burden” overlooks the fact that the rule has provided clarity and consistency for 25 years. Removing it will create a patchwork of forest-by-forest decisions, increasing administrative complexity and inviting conflict. The 2001 Roadless Rule is one of the most successful and broadly supported conservation policies in modern U.S. history. It protects values that cannot be replaced once lost. I strongly urge the USDA to keep the Roadless Rule intact and maintain national-level protections for these irreplaceable landscapes.

I strongly disagree with and oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001 / RIN 0596-AD66. As a Florida resident, mother, bird and wildlife photographer, I am deeply concerned about the potential effects of rescission on wildlife habitat, landscape connectivity, wildfire ignition risk, invasive species, watersheds, and the long-term fiscal costs associated with additional road construction and maintenance. My attached substantive comment provides supporting scientific and agency sources and asks the Forest Service to address several specific issues in the Final Environmental Impact Statement, including the cumulative effects of increased road access, the agency’s forest-health and wildfire justifications, the uncertainty surrounding projected timber and economic benefits, and the existing deferred-maintenance burden for Forest Service roads and bridges. I respectfully ask the Forest Service to consider my full attached comment and supporting sources as part of the administrative record and to retain the protections of the 2001 Roadless Area Conservation Rule. Thank you for considering my comment.

I am submitting this comment regarding the proposed rescission of the Roadless Area Conservation Rule and the Draft Environmental Impact Statement (DEIS). I am concerned that the economic case for rescission has not been demonstrated. If the purpose is to increase economic opportunity and improve management of public lands, the relevant question is whether rescission will produce a meaningful net economic benefit to the American public. The agency’s own analysis raises significant questions. 1. Projected timber revenue is a hypothetical maximum, not an expected return. The Forest Service identifies approximately 4.8 million acres where additional active management could potentially occur based on operability and existing land-management plans. It estimates that harvesting across all these areas annually could increase National Forest System sawtimber harvest by 5–10% and generate $5.2–$11.4 million annually in federal revenue. However, the agency acknowledges that harvesting all these areas annually is unlikely because of budgets, market conditions, and operability constraints. The final analysis should provide a reasonably foreseeable estimate of actual additional harvest and revenue rather than emphasizing a hypothetical upper-bound scenario. 2. New roads create long-term public liabilities. The Forest Service acknowledges an existing $6.9 billion deferred maintenance backlog for roads and bridges, while identifying road construction and maintenance costs as constraints on the benefits of rescission. Before treating new road access as an economic benefit, the agency should calculate its full lifecycle cost, including construction, maintenance, reconstruction, mitigation, and closure. The relevant calculation is: additional public revenue minus the full cost of infrastructure required to generate it. The DEIS does not demonstrate that this produces a positive return to taxpayers. 3. Recreation losses must be included in the net economic calculation. The agency estimates approximately $6.1 million annually in lost recreation economic benefits associated with affected areas. Those losses should be incorporated directly into the net-benefit calculation. If the agency presents $5.2–$11.4 million in potential annual federal timber revenue while identifying $6.1 million in annual recreation losses, the public should see the complete accounting of both. 4. The agency should explain potential impacts exceeding $100 million. The Federal Register states that additional impacts associated with the proposal could exceed $100 million and requests information concerning the range of economic impacts. The final analysis should identify what constitutes these impacts, whether they are costs, benefits, or transfers, which sectors experience them, and what assumptions produce the range. 5. Future opportunities should not be treated as realized economic benefits. The proposed rule does not authorize any specific timber sale or road project. Individual activities would depend on subsequent land-management and project-level decisions. The analysis should distinguish between economic activity reasonably expected to occur and activity that merely becomes legally possible. This matters because permanent infrastructure can create long-lived public costs even when the economic activity it facilitates remains uncertain. 6. Wildfire benefits should be quantified. The proposal identifies wildfire risk reduction as a potential benefit of increased access. The final analysis should quantify how much additional road construction is expected to facilitate fuels treatment or wildfire response, the resulting reduction in suppression or damage costs, and potential costs associated with increased access and ignition risk. A road that could provide access is not necessarily an economically realized wildfire benefit. Conclusion Public lands are public assets. Their management should be evaluated according to the net value they provide, not simply according to how many additional commercial activities become legally permissible. The Forest Service’s own analysis describes the potential opportunities as modest and localized, identifies a $6.9 billion road-maintenance backlog, estimates $6.1 million in annual recreation losses, characterizes the maximum timber scenario as unlikely, and acknowledges that additional economic impacts could exceed $100 million. Before rescinding the Roadless Rule, I ask the Forest Service to provide a transparent accounting of expected timber revenue, full lifecycle road costs, recreation losses, wildfire costs and benefits, impacts exceeding $100 million, and the economic value of retaining roadless areas. The proposed change should demonstrate a positive net economic return for taxpayers. The current DEIS does not yet establish that conclusion.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The country I grew up knowing exists because roads were never pushed through it, and that is precisely what this proposal threatens to change. The Forest Service cannot afford the roads it already has. "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." The agency's own environmental analysis acknowledges that road mileage, deferred maintenance costs, and management costs are all likely to increase if this rule is rescinded. Pushing new roads into country that currently has none will compound a fiscal problem the agency has not solved, and the consequence is not abstract: road construction fragments habitat, alters hydrology, and opens terrain to pressures that ecosystems built around roadlessness cannot absorb. Animals die. Environments that took generations to remain intact do not recover on a human timetable. I ask that the agency identify, by name and amount, the funding source it intends to use for any new road construction and maintenance under this proposal, and state specifically how the deferred maintenance backlog is projected to change. The agency's own cost-benefit accounting does not establish that this proposal is a net benefit to the public. The Cost Benefit Analysis states that "the net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million (-$70 to $152 million discounted at 7 percent) and uses maximum potential costs and benefits that do not account for uncertainty." That range runs from a $92 million loss to a $199 million gain, meaning the agency has not demonstrated a benefit, it has demonstrated a range wide enough to include substantial harm. The problem is made worse by what the cost column omits: road construction, which the same document prices at $80,000 to $100,000 per mile and roughly $500,000 per mile in Alaska, along with maintenance and fuel treatment costs the document itself quantifies, none of which appear to be fully included in the net present value calculation. The upper bound assumes maximum potential harvest that the analysis itself calls uncertain. The agency also claims impacts "could exceed $100 million" without showing the arithmetic that produces that figure, and every quantified annual line item in the analysis appears to be under $22 million. The Cost Benefit Analysis was placed in an agency file folder rather than on the docket. The agency must place that analysis on the public docket, restate the net present value with road construction, maintenance, and fuels costs included in the cost column, and publish the arithmetic behind the claim that impacts could exceed $100 million. The small-business certification that accompanies this proposal cannot be squared with the analysis sitting beside it. "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 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 examining the outfitters and guides who actually hold permits in the areas this proposal would affect. The analysis itself concedes some of those firms may lose those receipts entirely. Averaging harm across the national universe of small businesses does not measure the harm falling on the specific businesses exposed to it. The agency should withdraw the certification and perform an assessment focused on the small entities actually operating in the potentially affected roadless areas. Finally, the proposed rule acknowledges that what follows from rescission is not limited to the rescission itself. "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 cannot simultaneously declare the foreseeable consequences of its own action out of scope and ask the public to comment on them. If plan amendments expanding timber harvest and road construction are a foreseeable result of rescission, they are part of this action and must be analyzed as such. The agency must treat the foreseeable plan-amendment scenario, including any expansion of timber harvest area, as within the scope of this rulemaking and subject it to full analysis before finalizing anything. Sincerely, Sara Kobus Wilmington, DE

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The national forests of Washington State are where I go to connect with friends, family, and nature. Hiking and camping across Washington is, as I think of it, a home for my soul, and the roadless areas that make that possible, places like Eagle Rock in the Mt. Baker-Snoqualmie, and Green Mountain, Jupiter Ridge, Mt. Zion, Quilcene, Jefferson Ridge, and the other inventoried roadless lands of the Olympic National Forest, are the foundation of that experience. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. I am asking this agency to leave them intact and to withdraw the proposed rescission of the 2001 Roadless Area Conservation Rule. Washington already has a great deal of working forest land, land that grows trees for industry and is accessible by road. We do not need more land converted to that condition by opening roadless country to new construction. The right approach is to maintain and make the best use of the lands with roads that already exist. No need to build more forest roads. The agency's own data makes the maintenance argument for me: "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." Building new roads into country that currently has none, while that backlog sits unaddressed and the budget to address it has shrunk by so much, is not a coherent plan. I ask that the agency name the specific funding source for any new road construction and maintenance that rescission would enable, and state in the record the projected change in the deferred maintenance backlog that would result. The fire calculus in the agency's own analysis points in the same direction. "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 Eagle Rock area, the Olympic roadless units, and the other places where I hike and camp are safer from human-caused fire precisely because they are roadless. The agency must quantify the expected increase in human-caused ignitions that would follow from new road access in these areas and weigh that increase honestly against any claimed reduction in wildfire hazard before this proposal advances. The economic accounting in the supporting documents does not hold together. "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 flexibility analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas, and then concedes some of those firms may lose these receipts anyway. That is not a finding of no significant impact; it is an averaging away of a real impact on specific people. The agency should withdraw the small-business certification and conduct a genuine assessment focused on the small entities actually operating in the potentially affected roadless areas. This comment is itself a reliance interest of the kind the agency invited and then declined to weigh. "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." I have organized my outdoor life in Washington around the existence of roadless protections. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas, and countless people beyond me have made similar choices premised on these protections remaining in place. The agency must identify and weigh the reliance interests described in the comments it receives, including the one expressed here, before it can lawfully change course. These are public lands. The Forest Service held more than 600 public meetings and received 1.6 million comments to write the rule that protects them. It has held none to undo it. Any change of this magnitude requires an expansive public process, not a quiet reversal. The agency should deny this rescission. Arvia Morris Seattle, Wa.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Public land belongs to all of us, and the 63,351 acres held within Georgia's 23 inventoried roadless areas belong to future generations as much as to anyone alive today. I oppose rescission of the 2001 Roadless Area Conservation Rule and ask the agency to answer the specific points below on the record. Atlanta already has water issues, and the state of Georgia cannot absorb further damage to its water systems. Across the Southern region, which includes Georgia, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis establishes that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of those watersheds have impaired streams today, and opening them to road construction is the most direct way to change that. I ask the agency to explain, specifically and for Georgia's watersheds, how it accounts for the sediment risk roads introduce and what protections remain if the 2001 rule is removed. Building new roads into country that has none, when the agency cannot maintain the roads it already has, makes no fiscal sense. "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." The DEIS itself concedes that road mileage, deferred maintenance and management costs are likely to increase under this proposal. A logged stand grows back. A road does not. I ask the agency to name the funding source for any new road construction and maintenance this rescission makes possible, and to state the projected change in the deferred maintenance backlog. The small-business certification 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 regulatory flexibility analysis reaches its no-impact conclusion by spreading an annual expenditure loss across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas, and it concedes some of those firms may lose those receipts entirely. The agency should withdraw the certification and assess the impact on the small entities actually operating in or adjacent to the potentially affected roadless areas, not the national average firm. The agency has also invited reliance interests and then declined to weigh 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." Future generations deserve to experience nature fully and do not deserve the environmental fallout of sediment and damaged ecosystems this rescission will cause. That inheritance is a reliance interest. The agency should identify and weigh the reliance interests described in the comments it receives, including this one. Finally, the agency cannot declare plan amendments beyond the scope of this proposal and then invite public comment on them in the same breath. "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)." That posture asks the public to do the analysis the agency refused to do. The foreseeable scenario of expanded timber harvest and road construction should be analyzed as part of this action, not deferred to a future proceeding where today's commenters have no guaranteed voice. Public land should be managed to protect it from further development and maintained responsibly for nature and our ecosystem. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. I ask the agency to answer each of the points above before this proceeding closes. Sincerely, Dana H Atlanta, GA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Public lands belong to the public. That is the principle I bring to this comment, and it is the lens through which I read every page of this proposed rescission. The agency's own numbers expose a fiscal contradiction at the heart of this proposal. "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." The DEIS acknowledges that road mileage, deferred maintenance costs and management costs are all likely to increase if the rescission moves forward. My position is simple: fix the roads that are already there before making new ones. New roads disrupt habitats and degrade our national treasures, and the agency has not explained how it would pay for any of them. I ask that the agency name the specific funding source for any new road construction and maintenance this rule would enable, and state in concrete terms what the projected change in the deferred maintenance backlog would be. The cost-benefit picture is no cleaner. The analysis the agency relies on states that "the net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million (-$70 to $152 million discounted at 7 percent) and uses maximum potential costs and benefits that do not account for uncertainty." That range runs from a loss of $92 million to a gain of $199 million. A rule whose own economics span that interval has not demonstrated a benefit; it has demonstrated uncertainty. Compounding the problem, the cost column excludes road construction at $80,000 to $100,000 per mile, and roughly $500,000 per mile in Alaska, as well as maintenance and fuel treatment costs that appear elsewhere in the same document. The upper bound assumes maximum potential harvest the analysis itself calls uncertain. This document was published in an agency file folder, not on the docket, and the claim that impacts could exceed $100 million appears without supporting arithmetic anywhere in the record. I ask that the agency place the Cost Benefit Analysis on the docket, restate the net present value with its own quantified road and fuels costs included in the cost column, and show the arithmetic behind the $100 million threshold. This is yet another blatant act of selling out public rights for private gain, and nowhere is that clearer than in how the agency treats the businesses that depend on these lands. "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 flexibility analysis reaches its no-impact conclusion by spreading a $9 million annual expenditure loss across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas. The analysis itself concedes some of those firms may lose these receipts. That concession and that certification cannot coexist. The agency should withdraw the no-impact certification and assess the effects on the specific small entities operating in the potentially affected roadless areas, not the national average firm. The drinking water question deserves the same honesty. "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." That low impairment rate reflects the protection these areas have had. Roads and their facilities can produce up to 90 percent of the sediment from a timber sale, by the agency's own data. Opening these watersheds to road construction is a direct threat to the public water supply, and the DEIS does nothing more than gesture toward forest plans as a substitute safeguard, without identifying a single enforceable provision in any of them. The agency must identify, forest by forest, which specific plan provisions are equivalent in force to 36 CFR 294.12 and 294.13 for municipal watersheds. A general assurance is not an answer. Sincerely, Jon Conway Reno, Nevada

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The mountains of North Carolina are where I go to get exercise and to disconnect from the normal daily routine. I cannot imagine this country without them. The roadless areas within those mountains, all 172,416 acres across 38 inventoried areas, are part of what makes that possible. This proposed rescission would place all of it at risk, and I oppose it without qualification. The agency cannot afford the roads it already has, and nothing in this record explains how it would pay for new ones. The DEIS acknowledges that road mileage, deferred maintenance and management costs are all likely to increase under the proposal. The agency's own figures make that problem concrete: "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." Opening North Carolina's roadless areas to new construction means adding to a backlog the agency has spent two decades failing to address. I want the agency to name, specifically and in writing, the funding source for any new road construction and maintenance in these areas, and to state the projected change in that backlog under the proposal. The financial case for rescission has not been made. The agency's Cost Benefit Analysis states that "the net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million (-$70 to $152 million discounted at 7 percent) and uses maximum potential costs and benefits that do not account for uncertainty." A range that spans from a $92 million loss to a $199 million gain is not a demonstration of benefit. It is an admission that the agency does not know. That range becomes still less credible when the cost column excludes the road construction costs of $80,000 to $100,000 per mile that the same document quantifies. The Cost Benefit Analysis was placed in an agency file folder, not on the docket. I ask that the agency place it on the docket, restate the net present value with its own quantified road and fuels costs included in the cost column, and show the arithmetic behind any claim that impacts could exceed $100 million. The small-business certification in this rulemaking contradicts the analysis sitting beside it. "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 certification was reached by spreading losses across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. North Carolina alone sits within a Southern region where 378 municipal water intakes draw from watersheds containing roadless areas, which means recreation and tourism businesses tied to clean water and intact landscapes are concentrated exactly where the impacts would fall. The agency must withdraw that certification and assess the entities actually operating in these places. National forests are one of this country's, and the world's, few remaining national treasures. That is not sentiment; it is a statement about scarcity. The 2001 rule was written after more than 600 public meetings and 1.6 million public comments. This rescission has been pursued without any equivalent process. Disrupting the natural state of these places with roads and logging is the opposite of what the agency should be doing, and this comment represents precisely the kind of reliance interest the agency itself acknowledged when it solicited "any reliance interests in the current rule that could be affected by this proposal." The Cost Benefit Analysis weighs none of them. The agency is obligated to identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Ian H. Charlotte, NC

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Public lands in Washington belong to my son as much as they do to anyone alive today, and I want him to be able to explore them. That is what brings me to this comment opposing the rescission of the 2001 Roadless Area Conservation Rule. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. These are places where my family can still experience nature as it is, and where the next generation can do the same. A logged stand grows back. The agency itself has acknowledged that roads do not. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule protecting these areas. It has held none to undo it. Trees help clean the air, and anything we can do to protect air quality should be prioritized, not traded away. Our next generation will face plenty of challenges without inheriting fewer wild places and dirtier air than we had. On the question of roads and money: I want my tax dollars spent protecting and maintaining what already exists. The agency's own figures show that Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring. The DEIS states that road mileage, deferred maintenance and management costs are likely to increase under this proposal. Before rescinding a rule that has kept these areas intact, the agency must name the funding source for new road construction and maintenance and state, in plain terms, the projected change in that backlog. The agency's own fire data undercuts the case for opening these areas. "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." Any claimed reduction in wildfire hazard from new access must be weighed against that reality. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and show its work. Across the Pacific Northwest region, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The families who depend on those intakes have organized their lives around the assumption that these watersheds remain protected. So have the outfitters, guides and tour operators who hold permits in these forests. "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." That is not a minor omission. This comment is itself a reliance interest: a parent who has built expectations about what his son will be able to experience. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds. The regulatory flexibility analysis compounds the problem. "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 analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than looking at the businesses actually permitted in the affected areas. The agency should withdraw that certification and do the analysis it skipped, focused on the small entities that actually operate in these places, not a national average. Any action that moves toward privatizing or degrading the lands the next generation has to experience nature reduces what they inherit. I ask that the agency answer each of these points in the record and reconsider this rescission. Sincerely, Lauren Moussa Seattle, Washington

Public Comment on the Proposed Rescission of the Roadless Area Conservation Rule Docket No. FS-2025-0001 | RIN 0596-AD66 I am writing today to oppose the proposed rescission of the Roadless Area Conservation Rule of 2001 (Roadless Rule). This landmark Rule is commonsense, protects key ecological, community, and cultural values, and is integral to my and my family’s health and wellbeing. I am submitting these comments to express my personal views and to request that the United States Department of Agriculture keep the Roadless Rule intact. My home is in the Southern Appalachian Mountains, where our national forests are renowned for their globally significant biodiversity and for their recreational opportunities. I take my young sons hiking, foraging, camping, and swimming in our favorite roadless areas. We study plants, mushrooms, animal tracks, birds, salamanders, and geology in these roadless areas. They love to explore the forest’s waterways and we plan to teach them how to fish in these roadless areas. We delight in waterfalls and they learn self-confidence and self-reliance. They are learning to love to be outside and to understand the importance of being disconnected to technology, a critical element in today’s technology-laden existence. In particular, the inventoried roadless areas on the Nantahala-Pisgah National Forest where we visit the most that do not have additional layers of designated protection are Cheoah Bald, Tusquitee Bald, Mackey Mountain, the Black Mountains, and South Mills River. We are intimately connected to these places and my family depends on them to explore and connect to nature with no worries of roads and the commercial enterprises that they bring into our public lands. I understand that there are places where those do occur, but I appreciate that the Roadless Rule has created certainty for over 25 years around where that can and cannot occur, and that as a parent I can access these precious places to build precious memories as my children grow and learn. They are physical, emotional, and spiritual places for my renewal, respite, and inspiration. As a citizen and taxpayer of the United States, I value Roadless Areas for saving my tax dollars. As Taxpayers for Common Sense reports, “[r]epealing the Roadless Rule would cost taxpayers billions in subsidized road construction and maintenance, exacerbate taxpayer losses from money-losing timber sales, increase wildfire risks and the associated costs borne by taxpayers, and weaken the health of roadless areas that provide important commercial and recreational benefits to the American public.” I appreciate that Roadless Areas provide water filtering service for over 25 million people across the country, and that clean drinking water is an irreplaceable resource. Roadless Areas of the Chattahoochee National Forest provide a significant portion of the Chattahoochee River, the source of drinking water for the City of Atlanta, where I have over a dozen family members who rely on that water. Above all, I believe that the Roadless Rule should be maintained as it is for the inherent values these areas provide for themselves, the flora and fauna and the unfragmented wild nature therein. Nearly 450 threatened, endangered, and ESA proposed wildlife species depend on national forest roadless areas for their survival, and over 1,500 sensitive plant and animal species recognized by the Forest Service find habitat in Roadless Areas. The unfragmented nature of Roadless Areas provide connectivity and more resilient habitat. Roadless Areas are less likely experience invasive species infestation or human-caused wildfire. I am requesting that the U.S. Forest Service fully analyze the following elements in the Final Environmental Impact Statement: •the effects of rescinding the Roadless Rule on wildlife habitat connectivity and landscape fragmentation •cumulative effects at the landscape scale, rather than limiting analysis to the direct footprint of potential future road construction or timber-management activities •watershed, erosion, sedimentation, and aquatic-connectivity impacts associated with potential changes in road construction and management •meaningful government-to-government Tribal consultation and consideration of Tribal interests and knowledge throughout the decision-making process Thank you for the opportunity to provide my comments on the proposed rescission of the Roadless Area Conservation Rule of 2001. I am requesting that the U.S. Forest Service select the No-Action Alternative laid out in the DEIS and keep the Roadless Rule intact.

I am a resident of Western North Carolina and am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I do not believe increased roadway development in our remaining roadless National Forest lands is beneficial to Western North Carolina or to the long-term public interest. Roads are not simply lines on a map. Once constructed, they fragment forests, alter wildlife habitat, increase erosion and sedimentation, affect watersheds, require continuing maintenance, and can facilitate additional development and extraction. Hurricane Helene should be an important consideration in evaluating this proposal. Western North Carolina has just experienced a devastating demonstration of what extreme rainfall, flooding and landslides can do to mountain infrastructure. According to the U.S. Geological Survey, Hurricane Helene and the preceding rainfall produced as much as 30.8 inches of rain in 72 hours in western North Carolina and more than 2,200 identified landslides. More than half of the identified landslides damaged structures, disrupted roads, or intersected rivers. The consequences for transportation infrastructure were enormous. The North Carolina Department of Transportation reported that Helene damaged approximately 9,400 sections of state-maintained roads, 846 public bridges, and more than 1,700 pipes and culverts, with estimated road and bridge repairs approaching $5 billion. The Blue Ridge Parkway alone identified at least 57 landslides across nearly 200 miles in North Carolina following the storm. These facts do not demonstrate that every road causes a landslide, nor do they eliminate the legitimate need for roads required for emergency response or essential forest management. They do demonstrate that road construction and maintenance in steep Appalachian terrain carry real and continuing risks and costs. In my view, those risks argue for greater caution about creating additional roads—not for weakening protections against them. This issue is particularly important in Western North Carolina. The Pisgah and Nantahala National Forests contain approximately 152,000 acres protected by the Roadless Rule, representing about 15 percent of these national forests. MountainTrue has documented that roadless lands also contain important headwaters and watersheds serving local communities. In Macon County, for example, portions of the Cartoogechaye Creek watershed that supplies the Town of Franklin occur within an Inventoried Roadless Area. MountainTrue notes that additional roads in such areas could increase runoff and sediment pollution affecting drinking-water supplies. The Forest Service itself documented substantial Helene damage to National Forest streams and watersheds, including erosion, flooding, landslides, sediment deposition and other impacts requiring restoration work. I recognize that the Forest Service must manage National Forest lands for multiple purposes and that circumstances may require emergency access, wildfire response, public safety measures, ecological restoration or other carefully justified activities. Protecting roadless areas does not mean preventing responsible forest stewardship. What I oppose is broadly removing the national protection that has kept these remaining intact landscapes relatively free from permanent road development. Once a road enters a previously roadless forest, the resulting fragmentation and alteration of the landscape cannot simply be undone. Roadless lands provide public benefits that are difficult to replace: clean water, intact wildlife habitat, biological diversity, scenic landscapes, quiet recreation, and places where future generations can experience Southern Appalachian forests with minimal infrastructure. For these reasons, I respectfully request that the Forest Service: Withdraw the proposal to rescind the 2001 Roadless Area Conservation Rule; Maintain existing protections for Inventoried Roadless Areas; Retain restrictions on routine road construction and reconstruction in these areas; and Continue allowing narrowly tailored activities necessary for public safety, emergency response, ecological restoration and responsible forest stewardship. Hurricane Helene has reminded Western North Carolina of the enormous consequences that extreme weather can have on mountain infrastructure. At a time when communities are still rebuilding roads, bridges, watersheds and other essential infrastructure, I believe the prudent course is to protect the remaining roadless forests rather than create additional permanent roadway obligations. Western North Carolina does not need more roads into its remaining wild forests. We need to protect the forests, watersheds, wildlife habitat and intact mountain landscapes that already provide substantial public value without requiring additional infrastructure. Thank you for considering my comments. Greg Dillingham, Marshall, N.C.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Forest Service cannot maintain what it already has. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring. That number is not a projection; it is the agency's own accounting of where things stand today. Building new roads into country that has none would deepen that backlog, not relieve it. Why create more work and waste more taxpayer funds when the agency cannot keep up with the infrastructure it already owns? I ask that the agency name the funding source for any new road construction and maintenance contemplated under this proposal and state the projected change in the deferred maintenance backlog. Drinking water is already a global concern, and these roadless areas sit inside watersheds that feed water to roughly 24 million Americans, including me and my family. Fewer than 12 percent of those watersheds have impaired streams today. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and the proposal under review would remove the protections that have kept those watersheds largely intact. The agency must explain on the record how it weighs the sediment risk roads introduce against the drinking water quality that roughly 24 million people currently depend on. The agency has been down this road before, and it lost. The record shows 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. That dissatisfaction led to a state-by-state replacement that the Ninth Circuit struck down. The current proposal revives the same logic. I ask that the agency address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time the agency replaced the national rule with a state-by-state approach. The economic case for rescission is not made. The Cost Benefit Analysis states that the net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million (-$70 to $152 million discounted at 7 percent) and uses maximum potential costs and benefits that do not account for uncertainty. A range that spans from a $92 million loss to a $199 million gain is not a finding of benefit; it is an admission that the agency does not know. The cost column excludes road construction, maintenance and fuel treatment costs that the same document quantifies elsewhere, and the upper bound rests on harvest levels the analysis itself calls uncertain. The analysis was placed in a file folder rather than on the docket, and the claim that impacts could exceed $100 million appears with no supporting arithmetic. The agency must place the Cost Benefit Analysis on the docket, restate the net present value with road and fuels costs included in the cost column, and show the arithmetic behind that $100 million figure. The small-business certification is equally unsupportable. 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. Reaching a no-impact conclusion by spreading losses across every small firm in the sector nationally, rather than examining the outfitters and guides actually holding permits in the affected areas, is not a serious analysis. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. These are the last unroaded third of the national forests. A logged stand grows back; a road does not. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule that protects them. It has held none to undo it. It matters to me that these lands be protected for future generations, like my daughter and her children beyond that, and a decision of this magnitude made without a single public meeting raises a plain question: where is the voice of the people in this? Yours sincerely, Rachel Duvall Great Barrington, Massachusetts

October 6, 2026 Director, Ecosystem Management Coordination U.S. Forest Service Re: Proposed Rescission of the 2001 Roadless Area Conservation Rule Docket FS-2025-0001; RIN 0596-AD66 To Whom It May Concern: I live in Deer Lodge, Montana, have worked in Montana’s forest products industry for about 15 years, and serve as a volunteer firefighter. I am submitting this comment in my personal capacity. I support rescinding the 2001 Roadless Rule and adopting Alternative 2 of the Draft Environmental Impact Statement. In communities like Deer Lodge, timber supports steady employment for mill workers, loggers, truck drivers, mechanics, electricians, and many other skilled trades. Those businesses also support local suppliers, families, and public services. Losing a mill means losing much more than one employer. It can weaken the entire network needed to harvest timber, manufacture wood products, and carry out forest treatments. Rebuilding that capacity after it disappears is difficult. A dependable supply of economically usable timber is essential to keeping that infrastructure in Montana. Decisions on the Beaverhead-Deerlodge and Helena-Lewis and Clark forests are particularly relevant to my community. Timber can be abundant on the landscape and still be unavailable because access is restricted or the cost of reaching it makes a project impractical. Removing the Roadless Rule could allow better project boundaries, more practical access, and more efficient haul routes where forest plans permit them. Even incremental improvements can matter to a rural mill and the contractors who supply it. I recognize the limits of this proposal. Many roadless acres are steep, remote, or otherwise unsuitable for economical harvest. Rescission would not guarantee a large increase in timber production, eliminate litigation, or solve agency staffing and budget problems. My support is based on giving land managers the opportunity to evaluate workable projects on their merits. A modest increase in accessible timber, or a better-designed project that becomes economically feasible, can still provide meaningful local benefits. As a volunteer firefighter, I also want forest managers to have practical options for addressing hazardous fuels and providing safe access where conditions justify it. Strategically located roads can provide access and useful control points for suppression. Mechanical treatment and prescribed fire should be considered where appropriate to the forest type, terrain, and management objectives. I am not suggesting that every fire can be prevented or that every forest should be treated. I support evaluating those tools locally, with firefighter safety and community protection among the considerations. Access comes with responsibilities. Road construction and maintenance can affect water quality, habitat, and erosion, and public access can create additional ignition risks. Projects should account for those effects through careful location, maintenance, drainage, and appropriate access restrictions. Providing access for forest management does not require opening every road to unrestricted public travel. I value Montana’s wildlife, watersheds, recreation opportunities, and undeveloped landscapes. Rescinding this rule would leave applicable forest plans, the National Environmental Policy Act, the Endangered Species Act, and other legal protections in place. It would not remove congressionally designated wilderness protections. Those safeguards provide a framework for deciding where management is appropriate and where protection should remain the priority. Local conditions and public input should guide those decisions. I ask the Forest Service to consider the importance of retaining the mills and logging businesses needed to implement its forest-management objectives. National estimates of additional timber volume can obscure the value of a workable project to a particular community. Please evaluate benefits in terms of feasible treatments, affordable access, and timber that can actually be harvested and delivered. If the rule is rescinded, implementation will matter. The Forest Service should identify practical opportunities with local communities, Tribes, landowners, and industry; provide the staffing and resources to develop them; and track results beyond acres planned or timber sold. Communities need to understand what work can proceed, what remains constrained, and what has actually been accomplished. I support full rescission because it would remove an additional nationwide restriction and allow forest managers to make decisions suited to the lands and communities they serve. That flexibility would be a useful step toward sustaining Montana’s timber infrastructure and improving the options available for responsible forest management. Thank you for considering my comments. Christopher T. Anderson Deer Lodge, Montana

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Issue 2: Reliance interests are invited and never assessed I plan trips into these areas year after year, counting on the protection that keeps them what they are. That reliance is exactly what the agency asked commenters to describe. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Issue 3: The agency's own fire data cuts against the proposal I hike and camp in this country, and fire shapes every trip I plan. If the agency's own data ties ignitions to road access, I want that weighed honestly. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The effects analysis itself concedes that road access could increase the number and frequency of wildfires. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard. Issue 4: The agency cannot afford the roads it already has This is my money. Before the agency commits to building more, I want it to account for what it already cannot maintain. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring. The DEIS states that road mileage, deferred maintenance and management costs are likely to increase under the proposal. I ask that the agency name the funding source for new road construction and maintenance and state the projected change in the backlog. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Jaycie Weathers

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The wanton destruction and the capitalistic orgy of excess is a waste of every dime. I am already pretty sure my youngest children will be among the first to starve because of the already unchecked shit you people do. Seriously, the land should be managed by the native peoples who have already been scammed out of it 3 times. There is no excuse for this. There is no reason. Release the Epstein files, execute the wannabe dictator and for the love of all that is decent just stop breaking shit like angry toddlers. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The agency cannot afford the roads it already has This is my money. Before the agency commits to building more, I want it to account for what it already cannot maintain. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring. The DEIS states that road mileage, deferred maintenance and management costs are likely to increase under the proposal. I ask that the agency name the funding source for new road construction and maintenance and state the projected change in the backlog. Issue 2: The agency's own accounting cannot say if this makes money or loses it I care how my tax money gets spent, and I expect an honest accounting before public assets are traded away. The agency's own analysis cannot provide one. The Cost Benefit Analysis: "the net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million (-$70 to $152 million discounted at 7 percent) and uses maximum potential costs and benefits that do not account for uncertainty." The cost column excludes the road construction ($80,000 to $100,000 per mile, roughly $500,000 per mile in Alaska), maintenance and fuel treatment costs the same document quantifies, and the upper bound assumes maximum potential harvest the analysis itself calls uncertain. An economically significant rule whose own analysis spans from a $92 million loss to a $199 million gain has not shown a benefit; the analysis was published in an agency file folder rather than on the docket, and the rule's claim that impacts "could exceed $100 million" (91 FR 53830) appears with no arithmetic anywhere, though every quantified annual line item is under $22 million. I ask that the agency place the Cost Benefit Analysis on the docket, restate the net present value with its own quantified road and fuels costs included in the cost column, and show the arithmetic behind the statement that impacts could exceed $100 million. Issue 3: The small-business certification contradicts the analysis beside it I care where the costs of this decision land, because it is my money either way. The certification here does not survive the analysis printed beside it. 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. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Michael Mastropietro Girard, Ohio