Comment Analysis · Docket FS-2025-0001

FS-2025-0001-311406

Opposes rescissionA1 strongSubstance 12/24Owed an answerPosted September 3, 2026 On Regulations.gov

In short: The comment establishes that the agency's own data show road construction in roadless areas increases fire risk and that the economic case for rescinding the rule is weak, while also requesting specific burdens not covered by existing exceptions and withdrawing a small-business certification.

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, 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

Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Opening roadless areas to new construction does not reduce fire risk”
- “reconcile the rescission with the ignition data in its own draft environmental impact statement”
Water Quality Quantity
- “Our water comes from the Cibola National Forest, and we must protect it”
- “roads and their facilities can produce the overwhelming share of sediment from a timber sale”
- “expense of watersheds that are still largely unimpaired”
Recreation Tourism Public Use
- “There is nothing like being in the forest alone, no crowds”
- “recreation losses of at least $6.1 million a year”
- “places where children can learn to love and appreciate what is still intact”
Governance Policy Process
- “The rule as written 'generally banned road building subject to limited exceptions'”
- “The agency certifies no significant impact on small entities while its own DEIS names outfitters, guides and tour operators as affected”
- “The Forest Service held more than 600 public meetings and took in 1.6 million comments to build the rule. It has held none to undo it.”

What it names

National Forests: Cibola 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: Specific placeLocal knowledgeAnalytical gap

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 There is nothing like being in the forest alone, no crowds, just you and your spouse, listening for the call of an owl under dark skies. That is what the Cibola National Forest means to us. The proposal to rescind the 2001 Roadless Area Conservation Rule would put that at risk, and I oppose it. The threat I want to name first is fire. The agency justifies this rescission partly on wildfire and fuels management grounds, but its 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 Cibola is already under pressure, including from uranium prospecting that I believe represents exactly the kind of intrusion this rule was written to prevent. Opening roadless areas to new construction does not reduce fire risk; the agency's own data say it increases it. I ask that the agency explain why this proposal departs from those prior findings, and that it 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. Our water comes from the Cibola National Forest, and we must protect it. The agency's own record establishes that roads and their facilities can produce the overwhelming share of sediment from a timber sale, yet the economic case for rescission is thin at best. The agency's own text concedes: "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 must reconcile that admission with its own cost-benefit 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, a net present value spanning -$92 million to +$199 million, and a road system already carrying a $6.9 billion maintenance backlog. How does an action whose own analysis cannot establish a net benefit justify expanding that system at the expense of watersheds that are still largely unimpaired? I also want to note that the rule the agency proposes to eliminate already contains the flexibility it claims to need. The rule as written "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)." If specific permitting situations remain unaddressed by those exceptions, the agency has not identified them with any precision. I ask that it do so: name the specific burdens not already covered, and quantify them. Finally, the small-business certification attached to this proposal is not credible on its face. The agency certifies no significant impact on small entities while its own 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 in the sector nationally, rather than examining the guides and outfitters who actually hold permits in the affected areas, produces a meaningless average. The agency should withdraw that certification and assess the firms actually operating in these places. These roadless areas are, as I think of them, the jewels of our nation, found nowhere else. The Forest Service held more than 600 public meetings and took in 1.6 million comments to build the rule. It has held none to undo it. These are places where children can learn to love and appreciate what is still intact, places that bring something steady and grounding that developed land simply cannot. Letting uranium prospectors and road builders into the Cibola's roadless lands is not a trade I accept, and I ask that the agency address each of the concerns above directly and in full before this proceeding closes.