Comment Analysis · Docket FS-2025-0001

FS-2025-0001-308614

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted September 3, 2026 On Regulations.gov

In short: The comment establishes that the agency's economic analysis fails to demonstrate a net benefit for rescinding the 2001 Roadless Area Conservation Rule, specifically highlighting a $6.9 billion maintenance backlog, a net present value range that includes negative values, and a flawed small-business certification that ignores localized impacts on outfitters and guides in the Superior 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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Water Quality Quantity
- “hydrological engine of the Boundary Waters system”
- “filters through intact forest soils”
- “cleanest freshwater in the lower 48”
- “286 municipal water intakes sit in watersheds”
Recreation Tourism Public Use
- “recreation losses of at least $6.1 million a year”
- “loons on the clean lakes”
- “outfitters, guides and tour operators as affected”
- “re-grounded in my life and the world”
Economic Impact Fiscal
- “economic case for rescission collapses”
- “timber revenue to the Forest Service of only $5.2 to $11.4 million a year”
- “$6.9 billion maintenance backlog”
- “net present value ranging from negative $92 million”
Wildlife Habitat
- “true wild places left in Minnesota”
- “gray wolf, moose, Canada lynx, bald eagle, lake sturgeon, and northern long-eared bat”
- “roadless character of those 62,004 acres”
- “living creatures and nature to shape the land”

What it names

National Forests: Superior National Forest
Law cited: 36 C.F.R. Section 294.12

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 Superior National Forest is one of the few true wild places left in Minnesota. When I travel from the city up to Superior Forest in the north, I become re-grounded in my life and the world. That experience, the loons on the clean lakes, the stars I cannot see at home, the colors of the leaves, all of it depends on the roadless character of those 62,004 acres. Rescinding the 2001 Roadless Area Conservation Rule would put that at risk, and the agency's own record does not justify doing it. The economic case for rescission collapses under the agency's own numbers. The 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." Against those marginal gains, the agency's Cost Benefit Analysis projects timber revenue to the Forest Service of only $5.2 to $11.4 million a year, offset by recreation losses of at least $6.1 million a year and a net present value ranging from negative $92 million to positive $199 million. That spread does not establish a net benefit. There is almost no place left in Minnesota without roads. Why spend money degrading those few places when we need to spend the money to maintain the roads and bridges we already have? The agency carries a $6.9 billion maintenance backlog against a road budget of roughly $73 million a year, and it cannot explain how adding roads to a system it cannot already maintain serves the public interest. I ask that the agency reconcile the proposal's justification with these figures from its own analysis. The agency also claims administrative burden as a reason for rescission, but the rule already contains the flexibility it says is missing. The 2001 rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Existing mineral rights, public safety, and community wildfire protection are all addressed within the rule as written. The agency must identify, by name and by burden, which specific situations are not covered by those exceptions, and quantify that on the record. The Superior's roadless areas are the hydrological engine of the Boundary Waters system. Rain falls on unlogged ridges, filters through intact forest soils, and enters the lake system as some of the cleanest freshwater in the lower 48. The loons I watch from the shore depend on that water quality. So do the gray wolf, moose, Canada lynx, bald eagle, lake sturgeon, and northern long-eared bat verified in the Superior. Across the Eastern region, which includes Minnesota, 286 municipal water intakes sit in watersheds containing affected roadless areas. The agency's small-business certification ignores who actually bears the cost of degrading that system. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." Spreading that loss across every small firm nationally, rather than assessing the guides and outfitters holding permits in the affected areas, produces a meaningless average. The agency should withdraw the certification and assess the firms actually operating here. Finally, the agency solicited "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 such an interest. We are a nation built by taming the wilderness, but also built by keeping wild areas around the country that enable living creatures and nature to shape the land without human intervention. People have structured their relationship to places like the Superior around the protection the 2001 rule provides. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further. Sincerely, Lisa Pannell St Louis Park, Minnesota