Comment Analysis · Docket FS-2025-0001

FS-2025-0001-274292

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted August 27, 2026 On Regulations.gov

In short: The comment documents that the agency's rescission proposal fails to reconcile its own wildfire data and cost-benefit analysis with the proposed rule, and specifically requests that the agency restate its purpose and need based on forest conditions and analyze a fully protective alternative in compliance with NEPA.

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

Environmental Protection Biodiversity
- “biologically remarkable regions”
- “irreplaceable species”
- “Black bear, hellbender, brook trout, Indiana bat, northern long-eared bat, and Virginia spiraea”
Water Quality Quantity
- “378 municipal water intakes”
- “drinking water supplies”
- “watershed protections”
Governance Policy Process
- “alternatives analysis is the most fundamental procedural failure”
- “not a NEPA-compliant reason to foreclose an alternative”
- “purpose statement written entirely around deregulation”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “wildfire and fuels management as justification”
- “wildland-urban interface targeted alternative”

What it names

National Forests: Cherokee National Forest
Roadless areas: Bald Mountain

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The mountains of eastern Tennessee are part of who I am. As a native Tennessean, those ridges and hollows carry real weight for me, and the Bald Mountain roadless area inside the Cherokee National Forest is the kind of place that weight attaches to. The proposal to rescind the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, would put that place and the 84,881 acres of inventoried roadless land across Tennessee's 18 roadless areas at permanent risk. I oppose the rescission. The Cherokee's roadless pockets sit inside one of the most biologically remarkable regions on the continent. The southern Appalachians are an evolutionary crossroads: more tree species grow in forests like this one than in all of northern Europe. Black bear, hellbender, brook trout, Indiana bat, northern long-eared bat, and Virginia spiraea all have verified presence in the Cherokee. Across the Southern region, which includes Tennessee, 378 municipal water intakes sit in watersheds containing affected roadless areas. Opening these places to new roads does not simply change a land management rule. It puts irreplaceable species and drinking water supplies on a one-way path. I want the agency to explain in plain terms what species and watershed protections replace the rule once it is gone. On wildfire, the agency's own record says this: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That is the agency's own language. The rescission proposal nonetheless leans on wildfire and fuels management as justification for opening roadless areas to new construction. Those two positions cannot both be correct, and the agency has not reconciled them. I ask that the agency explain, drawing on its own ignition data, why nationwide road-building serves a fire-reduction purpose when its own findings point in the opposite direction. The economic case is no stronger. The agency's record already establishes that "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, with a net present value spanning -$92 million to +$199 million. The agency cannot establish a net benefit by its own numbers. It also cannot explain how expanding a road system already carrying a $6.9 billion maintenance backlog serves the public interest. The agency must reconcile the proposal with those figures before moving forward. The alternatives analysis is the most fundamental procedural failure. The agency dismissed every option that would have preserved roadless protections, not because forest conditions required it, but because more protective alternatives conflicted with deregulatory executive orders. The boundary-retention option was cut because it "would continue to restrict local decision-making discretion" and because analyzing roadless values is described as "an administrative and legal burden for the agency." That is not a NEPA-compliant reason to foreclose an alternative. A purpose statement written entirely around deregulation cannot generate the honest comparison of options that the law requires. I ask that the agency restate the purpose and need in terms of actual forest conditions and analyze at least one fully protective alternative before issuing a final rule. Finally, the agency built a wildland-urban interface targeted alternative that would have addressed fuels management concerns in the 9.8 million acres, 24 percent of the affected area, where roadless land overlaps with the interface as defined by HFRA, without rescinding the rule everywhere else. The agency's own DEIS says the benefits of added fuel-management access "would likely be modest and localized." The agency then rejected the targeted alternative in favor of nationwide rescission. That choice demands a coherent explanation, and none has been provided. Why was the narrower option, the one the agency itself designed to answer the fire rationale, set aside in favor of eliminating the rule entirely? That question deserves a direct answer in this record. Sincerely, M. Hill Ohio