Comment Analysis · Docket FS-2025-0001

FS-2025-0001-290853

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted August 31, 2026 On Regulations.gov

In short: The comment places on the record specific data from the agency's own EIS and Cost Benefit Analysis demonstrating that roaded lands have higher fire densities and that the projected economic benefits do not outweigh recreation losses, while simultaneously documenting the agency's failure to assess specific small business impacts or weigh the reliance interests of commenters in the Chugach 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

A3 weak: Substantive, but easier to set aside.

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.
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.
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.
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

Recreation Tourism Public Use
- “Time in nature is healthy and calming”
- “The variety of trails and options I have now is wonderful”
- “recreation losses of at least $6.1 million a year”
- “I have planned my recreation and my expectations for these places around a rule”
Forest Management Wildfire
- “The agency's own record demolishes the wildfire rationale offered for rescission”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reports far higher fire density on roaded land than inside the affected roadless areas”
- “explain why it is departing from its own prior findings”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value spanning negative $92 million to positive $199 million”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”
- “assess the actual impact on the specific permit holders operating in these roadless areas”
Governance Policy Process
- “The agency is now proposing to undo that without holding a single public meeting”
- “The agency has invited reliance interests and then declined to weigh them”
- “It must identify and weigh the reliance interests described in the comments it receives”
- “built through more than 600 public meetings and 1.6 million comments”

What it names

National Forests: Chugach National Forest
Roadless areas: Kenai LakeKenai Mountains

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Time in nature is healthy and calming. I go there to recreate, and I think about future generations every time I do. The variety of trails and options I have now is wonderful, and I want to keep them that way. What worries me most is something I keep coming back to: we have fewer green spaces than any generation before us, and once we build something, it lasts for lifetimes. That is why I am filing this comment against the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The Chugach National Forest, where the Kenai Mountains, Kenai Lake, and Resurrection roadless areas sit, is the most roadless national forest in the entire system. Ninety-nine percent of it has never had a road built through it. It holds 40 inventoried roadless areas totaling 5,439,110 acres. Alaska as a whole holds 150 inventoried roadless areas totaling 14,778,685 acres. Alaska is a wild place. I am asking this agency to keep it that way, and to explain in its final decision how opening any part of that landscape to roads serves a public interest that outweighs the permanent loss. The agency's own record demolishes the wildfire rationale offered for rescission. The 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." The proposal nonetheless invokes wildfire management as a reason to rescind roadless protection and expand the road system. The agency must 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, and explain why it is departing from its own prior findings. The economic case is no stronger. The agency's own 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." 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 spanning negative $92 million to positive $199 million. That range cannot establish a net benefit. The agency must explain on the record how it justifies expanding a road system already carrying a $6.9 billion maintenance backlog when its own numbers do not confirm a gain. The agency's treatment of small businesses is also contradicted by the record beside it. The supporting regulatory flexibility analysis reaches a no-significant-impact conclusion by spreading losses across every small firm in the sector nationally, rather than assessing the outfitters, guides, and tour operators actually holding permits in the affected areas, even though the agency concedes some of those firms may lose those receipts entirely. The Chugach hosts verified populations of brown bear, moose, mountain goat, bald eagle, trumpeter swan, and western sandpiper in the millions during migration. The wildlife-dependent small businesses that operate there are not a national average. I ask that the agency withdraw the small-business certification and assess the actual impact on the specific permit holders operating in these roadless areas. Finally, the agency has invited reliance interests and then declined to weigh them. 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. This comment is one such interest. I have planned my recreation and my expectations for these places around a rule that the Forest Service built through more than 600 public meetings and 1.6 million comments. The agency is now proposing to undo that without holding a single public meeting. It must identify and weigh the reliance interests described in the comments it receives, including this one, before it takes any final action. Sincerely, Shasta Gray Anchorage, Alaska