Comment Analysis · Docket FS-2025-0001

FS-2025-0001-266198

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted August 24, 2026 On Regulations.gov

In short: The comment establishes that the agency's analysis is incomplete because it excludes foreseeable impacts from future land management plan amendments, that the economic benefits of rescission are negligible compared to the existing road maintenance backlog, and that the small business certification is inconsistent with the document's own admission of potential impacts exceeding $100 million.

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, 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

Governance Policy Process
- “against removing a national standard and replacing it with the promise that project level review will catch whatever the standard used to catch”
- “An analysis that leaves out the foreseeable results of the action is not a good enough basis for taking it”
- “The small business certification does not line up with the rest of the document”
- “choose the No Action alternative and keep 36 CFR part 294, Subpart B as it stands”
Economic Impact Fiscal
- “The economics in the proposal do not support the stated purpose”
- “yearly upside comes to roughly three tenths of one percent of a road maintenance bill the agency already cannot pay”
- “Adding road miles on top of that backlog is not deregulation. It is a cost pushed down the road”
- “recreation and tourism could see trade offs”
Forest Management Wildfire
- “The wildfire argument does not match what I see in the field”
- “real limits are crew availability, contracting capacity, appropriated funding, burn windows”
- “Making 4.8 million acres eligible... does not create crews or contracts or mills”
- “more public access can raise the chance of human caused ignitions”
Tribal Sovereignty
- “the proposal itself reports that most of the Tribal governments consulted oppose the rescission”
- “That record should count for something”

What it names

Law cited: 36 CFR part 294 5 U.S.C. 553 7 CFR 1.28

The comment

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

Public Comment Opposing the Proposed Rescission of the 2001 Roadless Area Conservation Rule Docket: FS-2025-0001 RIN: 0596-AD66 Submitted via regulations.gov Comment deadline: September 21, 2026 To the Director, Ecosystem Management Coordination: I own and run a tree service company in Okanogan County, Washington. Vegetation management, hazard trees, and fuels work are how I make my living, in a valley that has burned several times in the last fifteen years. I am writing to oppose the proposed rescission of 36 CFR part 294, Subpart B. I am not against active management on these lands. I am against removing a national standard and replacing it with the promise that project level review will catch whatever the standard used to catch. The proposal calls that a reduction in regulatory burden. What it actually does is move the scrutiny from one settled decision onto a project by project process that is already short on staff, already slow, and already the part of the work that gets contested. The proposal admits its own analysis is incomplete. Under Summary of Potential Impacts, the Department says that later land management plan amendments and revisions could increase the area where timber harvest and road construction would be allowed, and could produce impacts beyond what is summarized in the analysis. It then sets those changes aside as outside the scope. That is the heart of my objection. Rescission does not approve any project on its own. It removes the floor, and the proposal states plainly that the new floor is whatever each forest plan says at the time, and that plans can be amended. An analysis that leaves out the foreseeable results of the action is not a good enough basis for taking it. The economics in the proposal do not support the stated purpose. The Department estimates $5.2 to $11.4 million a year in revenue to the Treasury and Forest Service, and $4.6 to $10.6 million a year to the timber industry. That is about $22 million a year at the top end. The same document cites a $6.9 billion deferred maintenance backlog on roads and bridges, and about $6.1 million a year in lost economic benefit to recreationists. Even using the most favorable numbers in the proposal, the yearly upside comes to roughly three tenths of one percent of a road maintenance bill the agency already cannot pay. Adding road miles on top of that backlog is not deregulation. It is a cost pushed down the road. Anybody who runs equipment for a living knows what an unmaintained road turns into, and what it does to the drainage below it. The wildfire argument does not match what I see in the field. The proposal treats the 2001 rule as the thing limiting mechanical thinning and fire control options. In this region the real limits are crew availability, contracting capacity, appropriated funding, burn windows, and the fact that there is almost no market for small diameter material. Making 4.8 million acres eligible, which is 16 percent of the forested area in the potentially affected roadless areas, does not create crews or contracts or mills. The proposal concedes as much when it says harvest across all of it is unlikely because of budgets, operability limits, and market conditions. The proposal also acknowledges that more public access can raise the chance of human caused ignitions. In a county where roadside starts are routine, that is not a small thing to trade away. The small business certification does not line up with the rest of the document. The Department certifies that the rule will not have a significant economic impact on a substantial number of small entities. Elsewhere the same document says additional annual impacts could exceed $100 million and that recreation and tourism could see trade offs. Recreation dependent small businesses in the Methow Valley and across the eastern Cascades are exactly the kind of small entities that certification is supposed to account for. I think it should be withdrawn and a full analysis prepared. What I am asking for is that the Department choose the No Action alternative and keep 36 CFR part 294, Subpart B as it stands. If certain roadless areas genuinely need more flexibility for community protection in the wildland urban interface, the existing petition process under 5 U.S.C. 553(e) and 7 CFR 1.28 is still available. That is the process that produced the Idaho and Colorado rules. Targeted exceptions for specific places are defensible. Rescinding the whole thing nationwide to get them is not. I will add that the proposal itself reports that most of the Tribal governments consulted oppose the rescission, and that the earlier comment period drew more than 220,000 letters on behalf of over 625,000 individuals. That record should count for something. Respectfully, Chris Moore - Owner, HingePoint Tree Service, Inc. Winthrop, Washington