Comment Analysis · Docket FS-2025-0001

FS-2025-0001-278474

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted August 27, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Area Conservation Rule contains internal contradictions regarding wildfire risk and economic benefits, fails to adequately analyze protective alternatives due to a deregulatory purpose, and lacks a coherent justification for nationwide rescission over a targeted wildland-urban interface alternative.

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.

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

Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “open roadless areas to road construction as a wildfire management tool”
- “reconcile the rescission with the ignition data in its own draft environmental impact statement”
Governance Policy Process
- “alternatives offering more protection were dismissed as not responsive to deregulatory executive orders”
- “purpose and need written as deregulation forecloses the environmental comparison”
- “analyse at least one protective alternative in full”
Recreation Tourism Public Use
- “I hike and camp there to find quiet and to rejuvenate”
- “recreation losses of at least $6.1 million a year”
- “I want future generations to have what I have found there”
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”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests near my home in the foothills of the Great Smoky Mountains provide something that cannot be replaced or rebuilt. I hike and camp there to find quiet and to rejuvenate. I have also seen what fire can do in that landscape, and I take the wildfire question seriously. That is exactly why the agency's reasoning on fire troubles me as much as anything else in this proposal. The agency's own record states: "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." Living where I do, in country that knows fire, I read that finding and I cannot understand how an agency that wrote those words now proposes to open roadless areas to road construction as a wildfire management tool. I ask the agency to explain why this proposal departs from its own prior findings on fire occurrence in roadless areas, and to reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is equally hard to follow. The agency's record 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." That is the agency's own characterization of the stakes on the extraction side. Against that, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. A range that wide, spanning a net loss to a net gain, cannot establish that the action produces a benefit. The agency has not explained how it justifies expanding a road system already carrying a $6.9 billion maintenance backlog on the strength of an economic analysis this uncertain. I ask it to do so, in plain terms, on the record. Public land is an irreplaceable resource, and the way alternatives were screened here raises a direct procedural problem. The agency's own record reflects that alternatives offering more protection were dismissed as not responsive to deregulatory executive orders, and that the option of keeping roadless boundaries was cut because it "would continue to restrict local decision-making discretion" and because analysing roadless values is "an administrative and legal burden for the agency." A purpose and need written as deregulation forecloses the environmental comparison that the National Environmental Policy Act exists to require. When the purpose excludes protection by definition, no protective alternative can survive the screening, and the public never sees the comparison. The agency should restate the purpose and need in terms of actual forest conditions and analyse at least one protective alternative in full. Finally, the wildfire rationale and the stated legal basis of the proposal do not fit together. The agency states that "the purpose and need is to reduce regulatory burden and return decisionmaking to local officials," and it also states that overlap with the wildland-urban interface as defined by the Healthy Forests Restoration Act is 9.8 million acres, 24 percent of the affected area, and that the benefits of added fuel-management access "would likely be modest and localized." The agency itself constructed and then rejected a targeted alternative limited to wildland-urban interface areas, an alternative that would have addressed the fire rationale without rescinding protections across the full area. Nationwide rescission goes far beyond what the fire argument, even if accepted at face value, could support. The agency needs to explain why it chose nationwide rescission over the more limited alternative it built and rejected. I manage to find quiet in those forests, and I want future generations to have what I have found there. That is not a recoverable thing once roads go in. These are not abstract concerns. Sincerely, Sue DuBois Walland, TN 37886