Comment Analysis · Docket FS-2025-0001

FS-2025-0001-301773

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted September 2, 2026 On Regulations.gov

In short: The comment places on the record specific deficiencies in the agency's economic and environmental analysis, citing DEIS Table 21 and 70 Fed.Reg. 25,656, and requests reconciliation of the proposed rescission with the agency's own findings on wildfire risk, sediment loading, and the Tenth Circuit's ruling on statutory authority.

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

Recreation Tourism Public Use
- “I hike and camp to become one with nature”
- “wild spaces God has given us need to remain wild”
- “recreation losses of at least $6.1 million a year”
Water Quality Quantity
- “preserve and protect our water sources”
- “378 municipal water intakes sit in watersheds containing affected roadless areas”
- “Roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “far higher fire density on roaded land than inside the affected roadless areas”
Legal Regulatory Framework
- “The Tenth Circuit held... the rule was within the authority Congress granted”
- “Ninth Circuit already reviewed what happens when this agency replaces a national rule with a state-by-state approach”
- “reconcile the proposal with its own economic analysis”

What it names

Roadless areas: Gum RunOak KnobSouthern MassanuttenThree Sisters

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 The wild spaces God has given us need to remain wild. I hike and camp to become one with nature, and the roadless areas I am writing to defend, across the George Washington, Jefferson, and Mendocino national forests, the areas called Gum Run, Oak Knob, Three Sisters, Southern Massanutten, and the others, are exactly the kind of places that rule protects. Virginia alone holds 64 inventoried roadless areas totaling 393,682 acres. Rescinding the 2001 Roadless Area Conservation Rule would put every one of them at risk, and I oppose that rescission. Public land should be managed for the public benefit, not to benefit administration officials with ties to the logging industry. Logging has destroyed our country's forests, and communities across the nation are still recovering from this loss of natural resource. The agency's own record states 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." That is the sum of what rescission buys. I ask that the agency reconcile the proposal with its own economic analysis, which 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 spanning -$92 million to +$199 million, and explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. I am a taxpayer. There is no reason to be expanding roads that will economically benefit only a select few. I want this land preserved for the sake of my neighbor's grandchildren, my boss's family, Republicans and Democrats 100 years from now. Land is tied to our nation, and we owe it to manifest destiny to preserve what we can. The proposal offers wildfire management as a justification for opening these areas to roads, but 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." The agency must explain why this proposal departs from those findings, and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. We need to preserve and protect our water sources. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own data show that about 24 million Americans drink water that starts in these watersheds. Roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Treading on those 24 million Americans who rely on this clean water is playing God. I ask the agency to address, specifically, what mitigation it proposes for sediment loading in watersheds like those feeding the intakes across the Southern region, and to explain what legal or scientific basis supports doing so. The agency argues that state-specific approaches can replace one national rule. But its own record shows "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit already reviewed what happens when this agency replaces a national rule with a state-by-state approach, and it did not end well for the agency. I ask that the agency address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and explain how this proposal avoids the deficiencies identified the last time this path was tried. The agency also argues the 2001 rule exceeded its statutory authority. That question has already been decided. The Tenth Circuit held: "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 court found the rule was within the authority Congress granted. The agency must explain on the record the legal basis for any contrary position. It is un-American and unpatriotic to rob future generations for short-term, oligarchical gain. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. My children should not inherit fewer of these places than I did. Shame on you. Sincerely, Michael J. North Carolina