FS-2025-0001-606520

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Appalachian mountains offer something increasingly rare: peace. They are among the only undeveloped areas in my region, and they need to stay that way. Roads would bring noise, light, and fragmentation, all things that would ruin prized camping ground, and I am submitting this comment because the proposed rescission of the 2001 Roadless Area Conservation Rule moves directly toward that outcome. The agency's own record undermines the wildfire rationale used to justify opening these areas. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the agency is now citing fuels management as a reason to rescind a rule that keeps roads out, it must explain how that argument survives its own data. I ask that the agency reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas, and that it explain why the proposal departs from these prior findings. The economic case for rescission is no stronger. The agency's own record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." I photograph the vast diversity of life within these forests, the canopies of endless green, the mammals, fish, insects, reptiles, amphibians, flowers, trees, mushrooms, and grasses that make up what development would put on a path toward extinction. All of that has value, and the agency's own Cost Benefit Analysis cannot establish that destroying it produces a net benefit, projecting timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. Working people in my city expect the money taken from their paychecks to go toward the functioning of their society, not toward expanding a road system already carrying a $6.9 billion maintenance backlog while city roads crumble. The agency must explain on the record how an action whose own analysis cannot establish a net benefit justifies that expansion. Related to that recreation loss is a regulatory flexibility problem the agency has not resolved. "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 expenditure losses across every small firm in the sector nationally rather than examining the outfitters and guides actually holding permits in the affected areas, and the analysis itself concedes some firms may lose these receipts. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not some national average firm that has no permit at stake. Finally, the agency solicited reliance interests, and this comment is one. "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." The peace and biological richness I depend on for hiking and photography in the Appalachian mountains exist because roadless protections have held. Supporting families does not require the destruction of life, and we are well past the point where that trade is necessary. The agency invited these reliance interests into the record and must now identify and weigh them, including this one. Sincerely, Ryan McArthur Atlanta, Georgia