Comment Analysis · Docket FS-2025-0001

FS-2025-0001-270675

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted August 26, 2026 On Regulations.gov

In short: The comment establishes that the agency's record contains internal contradictions regarding economic benefits, regulatory flexibility impacts on small entities, unaddressed reliance interests, and wildfire risk data that undermines the safety rationale for rescinding the Roadless Area Conservation Rule in the Chippewa National Forest.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, Evidence.

Standard dismissals it defeats

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.

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.
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.
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.
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.

Topics

Water Quality Quantity
- “protect watersheds”
- “286 municipal water intakes sit in watersheds containing affected roadless areas”
- “puts that water protection at risk”
- “watershed safeguards the rule currently provides”
Recreation Tourism Public Use
- “quiet and solitude of the roadless area”
- “hiking and camping to get away from the city”
- “paddle many of the watersheds”
- “recreation losses of at least $6.1 million a year”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
- “claimed reduction in wildfire hazard cannot rest on data showing that roaded land burns at more than seven times the rate of roadless land”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value ranging from -$92 million to +$199 million”
- “road system the agency would be expanding already carries a $6.9 billion maintenance backlog”
- “certifies no significant impact on small entities”

What it names

National Forests: Chippewa National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The quiet and solitude of the roadless area in the Chippewa National Forest in northern Minnesota is why I go there, often going hiking and camping to get away from the city. I also paddle many of the watersheds in Minnesota. I believe public lands should be managed to sustain wildlife habitat, protect watersheds, and maintain places to recreate. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens all three of those purposes, and the agency's own record does not support the action. Minnesota holds 16 inventoried roadless areas totaling 62,081 acres. Those acres include watersheds I paddle, and across the Eastern region, which includes Minnesota, 286 municipal water intakes sit in watersheds containing affected roadless areas. Rescinding the rule puts that water protection at risk without any demonstrated offsetting benefit, and I ask the agency to explain on the record what specific protections will replace the watershed safeguards the rule currently provides. The agency's economic justification does not hold together. The record before the agency states: "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." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million. The road system the agency would be expanding already carries a $6.9 billion maintenance backlog. I ask the agency to reconcile those numbers and explain how an action whose own analysis cannot establish a net benefit justifies adding to that backlog. The regulatory flexibility analysis presents a related problem. The agency certified no significant impact on small entities, yet "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 the $9 million annual expenditure loss across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. The analysis itself concedes some firms may lose those receipts. The agency should withdraw the certification and assess the impact on the small entities actually operating inside the potentially affected roadless areas, not the national average. Reliance interests are also unaddressed. "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." I have organized my recreation around the protections this rule has provided. When an agency changes course, it must assess the reliance interests its prior policy created. This comment is one such interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Finally, the agency's own fire data undermines the safety rationale for rescission. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014–2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis itself concedes that road access could increase the number and frequency of wildfires. The claimed reduction in wildfire hazard cannot rest on data showing that roaded land burns at more than seven times the rate of roadless land. The agency should quantify the expected increase in human-caused ignitions from new road access and weigh it against whatever wildfire reduction it claims before this rule moves forward. Sincerely, Rachele Krivichi St. Paul, MN