FS-2025-0001-610152

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