Comment Analysis · Docket FS-2025-0001

FS-2025-0001-306163

Opposes rescissionA2 moderateSubstance 18/24Owed an answerPosted September 3, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission of the roadless rule is factually unsupported by fire data, contains a specific arithmetic error in Table 1 regarding forgone benefits, relies on an incomplete biological assessment and Section 7 consultation, and fails to analyze tribal-requested alternatives, thereby documenting a significant deficiency in the agency's analysis.

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
- “researches wildfire and heat/drought impacts”
- “roads increase human-caused fire”
- “Increased public road access will raise the number and frequency of wildfires”
- “limiting rescission to within a half mile of existing roads”
Environmental Protection Biodiversity
- “negatively impact at least 300 listed species”
- “45 designated critical habitats”
- “grizzly bears, wolverines, gray wolves, Canada lynx, Mexican wolves, and fisher cats”
Economic Impact Fiscal
- “makes NO economic sense and is wasteful to American taxpayers”
- “net present value range of negative $92 million to positive $199 million”
- “timber benefit of $9.9 to $22.0 million has to be weighed against $6.1 million in recreation losses”
Legal Regulatory Framework
- “biological assessment is a draft and incomplete”
- “Section 7 of the draft consultation is incomplete”
- “not a lawful basis for a final rule”

The comment

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

I am a forest scientist who researches wildfire and heat/drought impacts on western US forests in OR, WA, CA, and CO. I am writing to strongly object to the proposed removal of the roadless rule, which purportedly is about reducing wildfire risk. This is FALSE - the rescinding of the roadless rule is really a timber and deregulation rule that mentions fire but is not about fire at all. Fire ignition data, including the USFS's 2001 finding that roads increase human-caused fire, rebut the rationale behind this proposed change. People start most fires in the American west. Increased public road access will raise the number and frequency of wildfires, without doubt. And USFS forest management plans already restrict harvest on 26.7 million acres regardless of the roadless rule. Additionally, the USFS cannot even maintain the forest roads it has already built, as it has a roughly $6.9 billion maintenance backlog on its roads! In addition, the proposed change makes NO economic sense and is wasteful to American taxpayers like myself. The USFS' own cost-benefit analysis shows a net present value range of negative $92 million to positive $199 million over fifteen years. The timber benefit of $9.9 to $22.0 million has to be weighed against $6.1 million in recreation losses and $5.3 to $11.5 million in forgone passive use. And there is a glaring arithmetic error: Table 1 lists minimum annual forgone benefits as $5.3 million while footnote 6 says costs include both the $6.1 million recreation loss and the $5.3 to $11.5 million passive use loss. The minimum should be $11.4 million! Critically, the biological assessment is a draft and incomplete. Even the draft finds this action is likely to negatively impact at least 300 listed species and some 45 designated critical habitats. The impacted species include grizzly bears, wolverines, gray wolves, Canada lynx, Mexican wolves, and fisher cats. Section 7 of the draft consultation is incomplete. A 30-day comment period based on on an incomplete biological assessment is not a lawful basis for a final rule. In conclusion, I am urging you to select Alternative 3, or better yet, no change to the Rule. The USFS' own analysis shows that limiting rescission to within a half mile of existing roads and the wildland-urban interface captures roughly 80% of the timber benefit on a fraction of the footprint — this is exactly where the fire prevention rationale is strongest! Why is the propsoal not focused on this if it's about fire? Also, please consider alternatives that multiple tribes requested that the agency did not analyze. Thank you.