Opposes rescissionA1 strongSubstance 7/24Owed an answerPosted October 7, 2026 On Regulations.gov
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A1 strong: Must be answered — it names the law.
Owed an answer on Legal.
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I write to oppose rescinding the 2001 Roadless Area Conservation Rule (the Roadless Rule). The United States Department of Agriculture (USDA) has insufficient information to understand the effects this action will have upon the environment and local communities in areas of increased road development.
Under the Supreme Court's decision in Seven County Infrastructure Coalition v. Eagle County, Colorado (Seven County), the USDA must evaluate environmental impacts that are reasonably foreseeable under a rule change. In its environmental impact statement, USDA did not fully consider the impacts of road development in previously undeveloped forest land on soil, air, and water quality; plant and animal communities, including threatened and endangered species; or forest health. USDA justified this omission because "it is uncertain if there would be any future project-level decisions, and what those decisions might entail."
This argument is patently absurd. USDA proposes a rule that would allow the development of roads where road development was not previously allowed. It then claims uncertainty as to what projects would result from this proposal. To clarify this uncertainty, I suggest to the USDA that allowing the development of roads will result in road development projects. Road development is not only a reasonably foreseeable impact but a straightforwardly obvious impact of rescinding the Roadless Rule. USDA is therefore obligated by the National Environmental Policy Act (NEPA) to prepare a full environmental impact statement evaluating the likely consequences, possibility of mitigation, and alternatives to road development in previously roadless areas.
USDA's justification for rescinding the Roadless Rule is to increase multiple-use opportunities and allow management for wildfires, insect and disease infestations, and community protection. While USDA may not be able to determine every road project that will occur if the Roadless Rule is rescinded, it can easily note areas currently in need of wildfire or disease management or where roads would increase multiple uses. In every such instance, a road would not be permitted under current regulations and would be permitted if the proposed rule were finalized. Each potential road development is therefore a reasonably foreseeable consequence of rescinding the Roadless Rule. The impacts of each must be included in an EIS under NEPA and Seven County. I request USDA identify a range of potential road development in currently roadless areas if the Roadless Rule is rescinded. I further request that, across this range, USDA assess the environmental impacts of road development development on soil, air, and water quality; plant and animal communities; and forest health. I finally request USDA fully consider the environmental impacts of road development on the environment and local communities in its consideration of rescinding the Roadless Rule. Without this full assessment, USDA lacks sufficient information to ascertain whether rescinding the Roadless Rule will actually achieve its purported goals.
USDA's environmental impact statement declined to consider the impacts that this proposed rule, if finalized, would have upon the environment and local communities. Because USDA has not accounted for the impacts of road development in this rule intended to allow road development, I strongly oppose finalizing the proposed rule for Special Areas: Roadless Area Conservation, 2026 FR 16965.