Comment Analysis · Docket FS-2025-0001

FS-2025-0001-281037

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted August 28, 2026 On Regulations.gov

In short: The comment places on the record specific contradictions between the agency's wildfire ignition data (DEIS Table 21) and its proposal to open roadless areas to roads, alongside evidence that the agency's Cost Benefit Analysis fails to establish a net benefit due to high recreation losses and an existing road maintenance backlog.

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

Forest Management Wildfire
- “wildfire rationale given for this proposal conflicts directly with the agency's own findings”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas”
Environmental Protection Biodiversity
- “protecting the last wild headwaters of rivers flowing to both the Atlantic and the Gulf”
- “black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat”
- “responsible conservation of public land is of extreme importance”
Legal Regulatory Framework
- “The Tenth Circuit found the 2001 rule was within the authority Congress granted under the Organic Act”
- “The agency must state on the record what legal basis, if any, supports a contrary reading of that authority”
- “small-business certification in this rulemaking cannot stand as written”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”

What it names

National Forests: White River National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Natural places hold a central and deeply meaningful place in my life. I hike and camp regularly across Colorado, particularly in the Arapaho, White River, and San Isabel National Forests, and I have spent considerable time in the Southern Appalachians as well, including Pisgah, Nantahala, and Cherokee National Forests. I'm drawn to these places by the scenery, wildlife, clean air, recreational activities, and a deep peace that comes from being in forests that still feel whole. I believe responsible conservation of public land is of extreme importance, and I am filing these comments to oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The wildfire rationale given for this proposal conflicts directly with the agency's own findings. The agency's 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." I often hike in the White River National Forest, which holds 90 inventoried roadless areas totaling 639,604 acres. The idea that opening those areas to roads reduces fire risk is contradicted by the agency's own ignition data. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask that the agency explain, point by point, why this proposal departs from its own prior findings on fire occurrence and how it reconciles the rescission with those numbers in its own record. The economic case is equally weak. The agency's record acknowledges: "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 forests of Nantahala and Pisgah, where I have also spent considerable time, hold 52,304 acres and 99,369 acres of inventoried roadless areas respectively, protecting the last wild headwaters of rivers flowing to both the Atlantic and the Gulf, alongside black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat. The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. The agency must reconcile that range with the proposal's stated purpose, and must explain how expanding a road system already carrying a $6.9 billion maintenance backlog is justified when the agency's own analysis cannot establish a net benefit. On legal authority: the proposal suggests the 2001 rule exceeded statutory authority. The courts that reviewed this directly held otherwise. The agency's record includes: "Exercising jurisdiction pursuant to 28 U.S.C. § 1291, we REVERSE the district court’s order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must state on the record what legal basis, if any, supports a contrary reading of that authority after that holding. Finally, the small-business certification in this rulemaking cannot stand as written. It reaches a no-significant-impact conclusion by averaging a projected $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters, guides, and tour operators actually holding permits in the affected areas. The agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year, and the record concedes some firms may lose those receipts. Dividing forests with roads would be a perilous decision for those businesses as well as for the forests themselves. The agency should withdraw the certification and conduct a genuine assessment of the small entities actually operating in the potentially affected roadless areas. Protection and strengthening of roadless areas is crucial to the health and longevity of our country and our planet. These comments are filed in that conviction. Sincerely, Steve Wood Boulder, Colorado