Comment Analysis · Docket FS-2025-0001

FS-2025-0001-229596

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted August 21, 2026 On Regulations.gov

In short: The comment establishes that the agency's justification for rescinding the 2001 Roadless Area Conservation Rule is unsupported by its own data regarding treatment capacity, fiscal net benefits, and wildfire ignition risks, while documenting that the current petition process already allows for state-specific tailoring without full rescission.

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
EA analysisEngages the agency's environmental analysis directly.
Analytical gapIdentifies something the analysis fails to address.
EvidenceBacks claims with specific facts, data, or research.
RequestMakes a specific, actionable request of the agency.
AlternativeProposes a different course of action.
LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Alternative, Legal.

Standard dismissals it defeats

Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Still open to the agency

Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.

Topics

Forest Management Wildfire
- “wildfire is not theoretical where I am”
- “roads carry ignitions”
- “thin the WUI, cut fuel breaks”
- “rescission is not that tool”
Economic Impact Fiscal
- “economics do not clear the taxpayer bar”
- “net negative”
- “deferred maintenance backlog”
- “outdoor recreation was $1.3 trillion in output”
Governance Policy Process
- “reduces local control”
- “more federal process, more litigation”
- “30 days with no public meetings”
- “scope it to the wildland-urban interface”
Recreation Tourism Public Use
- “lost recreation benefit”
- “I camp on Forest Service ground”
- “photograph the night sky”
- “lodging, fuel, food and retail businesses”

What it names

Law cited: 5 U.S.C. 553 E.O. 14192

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal

RIN 0596-AD66 / Docket FS-2025-0001 Comment on the Proposed Rescission of the 2001 Roadless Area Conservation Rule and the Draft EIS I oppose full rescission. I support the No Action alternative. If USDA needs more flexibility, scope it to the wildland-urban interface and use the petition process that already exists. My objections come from the agency's own preamble. To be clear up front: I am not against active management. I live in the West, in fire country, and wildfire is not theoretical where I am. Thin the WUI, cut fuel breaks, salvage dead stands, run prescribed fire. I will back all of it. Rescission is not that tool, and the record shows why. 1. ACCESS IS NOT THE BINDING CONSTRAINT. CAPACITY IS. The preamble states 11.3 million roadless acres (28.3%) already sit within a half mile of an existing road. The Chief states only 5% of high-hazard roadless acres have been treated since 2014. If access were the limiting factor, those 11.3 million already-reachable acres would be treated. They are not. The constraint is crews, contracts and appropriations. Request: the FEIS should disclose treatment rates inside versus outside IRAs, and inside versus outside that half-mile band. If the rates are comparable, the purpose and need fails on the agency's own data. 2. THE ECONOMICS DO NOT CLEAR THE TAXPAYER BAR. Preamble figures: $5.2M-$11.4M per year to the Treasury and Forest Service, $4.6M-$10.6M per year to the timber industry, against an acknowledged $6.9 billion deferred maintenance backlog on roads and bridges and roughly $6.1M per year in lost recreation benefit. Best case, the timber upside is a rounding error against the backlog and is largely cancelled by the recreation loss. At the low end of the agency's own range it is net negative. Request: model full lifecycle cost per new road mile (construction, maintenance, culverts, decommissioning) and disclose the net fiscal position. Adding assets we cannot maintain is how the backlog reached $6.9 billion. 3. ROADS CARRY IGNITIONS. THAT IS THE AGENCY'S OWN SCIENCE. Roughly nine in ten wildfires are human-caused. Forest Service researchers mapped 26 years of ignitions along about 850 miles of road in the Angeles, San Bernardino, Los Padres and Cleveland National Forests. The preamble itself concedes that greater access "can increase human-caused ignition potential." Request: quantify it. Model expected additional ignitions per new road mile against expected acres treated and show the net change in community risk. Right now the fire rationale is asserted, not calculated. 4. THIS REDUCES LOCAL CONTROL. IT DOES NOT INCREASE IT. Idaho and Colorado already built their own roadless rules by petition under 5 U.S.C. 553(e), and this proposal leaves both intact. That is proof the current framework is not one-size-fits-all. States that wanted tailoring got it. Full rescission does not hand decisions to local officials. It removes the floor and pushes every acre into plan revisions and project-level NEPA: more federal process, more litigation, more delay. That runs against the stated deregulatory purpose of E.O. 14192. 5. RELIANCE INTERESTS, SINCE THE PREAMBLE ASKS FOR THEM. Twenty-five years of private investment sits on this rule. Outfitters, guides, ranchers whose operations depend on intact headwaters, and the lodging, fuel, food and retail businesses in gateway towns whose product is the country next door. I am on the customer side of that economy, and my money goes to those towns because of what surrounds them. In 2024 outdoor recreation was $1.3 trillion in output, 2.4% of GDP and 5.2 million jobs, and hunting and shooting was the fastest-growing category in it at 16.5%. A projected $6.1M annual recreation loss does not credibly describe that exposure. It is a placeholder. 6. TAILORING. The community-protection rationale rests on WUI overlap: 9.8 million acres, 24%. Rescinding 100% of the rule to reach 24% of the acres is not narrow tailoring. A WUI-scoped alternative delivers the fire benefit without the rest, and I would support it. 7. PROCESS. The 2001 rule came out of 600 public meetings and 1.6 million comments. This round is 30 days with no public meetings, on a proposal the preamble concedes could exceed $100 million in annual effects. That gap will be the first thing a court looks at. One last thing. I camp on Forest Service ground, dispersed sites off forest roads across the Eastern Sierra, the Great Basin and the Northern Rockies. I photograph the night sky out there because dark sky has a hard boundary: it exists where roads and lights do not, and there is less of it every year. That country is an asset on the national balance sheet, and it took 25 years to stop borrowing against it. Roosevelt understood you do not liquidate the principal to make a quarter. Keep the rule. Fund the treatments. Use petitions where states want something different. A supporting statement with citations and a fiscal table is attached.