FS-2025-0001-572644

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Serene, remote places matter. I camp and hike to experience nature, and I photograph the rivers, forest and wildlife of the Oconee-Chattahoochee National Forest across the wilderness areas. Turner Creek, Boggs Creek, Cedar Mountain, Helton Creek and Duck Branch, all inventoried roadless areas in the Chattahoochee National Forest in Georgia, are the kinds of places I go looking for that quiet. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The Chattahoochee holds 23 inventoried roadless areas totaling 63,351 acres. These include black bear, brook trout, cerulean warbler, hellbender and the northern long-eared bat. When I photograph wildlife in these wilderness areas, I am documenting something that took a very long time to persist here. We cannot ruin areas like this, because they are near impossible to bring back to the same state once activities are started. A logged stand grows back. A road does not. I also ride forest roads and OHV areas on my motorcycle, so I understand road management from the user side. The agency needs to direct resources to maintaining and improving existing infrastructure rather than expanding and creating a negative feedback loop of destroyed infrastructure. The agency's own record states: "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." Increasing the number of roads is only going to make the Forest Service's job harder. I ask that the agency name the specific funding source for any new road construction and maintenance in currently roadless areas and state the projected change in the deferred maintenance backlog that would result from this rescission. The economic case for rescission is not established. The agency's own Cost Benefit Analysis states: "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 to a gain. It does not demonstrate a benefit. The cost column excludes road construction, maintenance and fuel treatment costs that the same document quantifies elsewhere. Our public land needs to prioritize recreational activities because they promote a healthier economy in the surrounding area. Too much emphasis is placed on destructive activities and unmaintainable development. The agency must place the Cost Benefit Analysis on the public 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 a specific dollar threshold. 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. Across the Southern region, which includes Georgia, 378 municipal water intakes sit in watersheds containing affected roadless areas. Communities tied to clean water and recreation depend on what these roadless areas protect. The agency reached its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The agency should withdraw that certification and assess the impact on the small entities who are actually operating in and around these roadless areas. Finally, the agency is asking the public to comment on consequences it simultaneously declares out of scope. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). I want my kids to inherit a healthier and better treed forest system than I did. I want the next generation to feel like they aren't constantly fighting for the survival of wilderness in the face of people trying to destroy our shared forest system. The agency cannot ask the public to do the analysis it has refused to do. It must analyze the foreseeable plan-amendment scenario, including expanded timber harvest area, as a direct component of this rulemaking before any final decision is made. Sincerely, Travis DeLoach Dahlonega, GA