Comment Analysis · Docket FS-2025-0001

FS-2025-0001-315838

Opposes rescissionA1 strongSubstance 18/24Owed an answerPosted September 4, 2026 On Regulations.gov

In short: The comment places on the record a specific request for the agency to reconcile the proposed rescission of the 2001 Roadless Area Conservation Rule with its own economic data showing a net negative cost-benefit analysis and to analyze site-specific environmental consequences for the Big Frog Addition and Bee Cove roadless areas.

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

Recreation Tourism Public Use
- “no roads, no cars, walking in and out is the only way”
- “hiking and backpacking crosses forest service roads that are co-opted by ATVs and Jeeps”
- “recreation losses of at least $6.1 million a year”
- “Losing these places would be a devastating blow”
Environmental Protection Biodiversity
- “there needs to be some remaining old growth, more inaccessible wilderness”
- “These forests are so unique because we accidentally saved them”
- “effects of the road construction and timber harvest it would newly allow”
- “retain the 2001 rule's protections”
Economic Impact Fiscal
- “The money doesn't add up”
- “timber revenue to the Forest Service against recreation losses”
- “net present value spanning -$92 million to +$199 million”
- “road system already carrying a $6.9 billion maintenance backlog”
Climate Carbon Storage
- “large trees accounted for 3% of the 636,520 trees... but stored 42% of the total AGC”
- “AGC is aboveground carbon”
- “Mildrexler, Berner, Law, Birdsey and Moomaw 2020”

What it names

National Forests: Cherokee National Forest Sumter National Forest
Roadless areas: Bee CoveBig Frog AdditionBig Mountain
Law cited: 66 FR 3244
Works cited: 2020 FEIS

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Big Frog is an impressive and imposing wilderness . It is the last area near me where there are no roads, no cars, walking in and out is the only way. So much of my hiking and backpacking crosses forest service roads that are co-opted by ATVs and Jeeps, even the most remote places end up being overrun. A little further away, the Bee Cove and Big Mountain areas. I've gone to the Foothills Trail and Bartram Trall areas in and around the roadless areas in the Sumpter and Nantahala national forests for the last 12 years. One thin that is easily seen as you go through other areas that are not roadless, is how often you see the impact of people on these forests. I've seen the managed forests be logged, and I understand it. However, there needs to be some remaining old growth, more inaccessible wilderness. Losing these places would be a devastating blow. These forests are so unique because we accidentally saved them, and they aren't perfect, they weren't so amazing that they were preserved on principle, but their simple nature is why they are so special. They are a basic kind of place that soon will disappear too. Then what? we preserve the last handful? I tell my grandkids how "all the forests used to look like this one" I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Big Frog Addition (369 acres), Cherokee NF, Tennessee - Bee Cove (3,025 acres), Sumter NF, South Carolina I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The money doesn't add up The proposal justifies rescission in part on timber economics and employment grounds. The record before the agency 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." (66 FR 3244, national social and economic effects discussion (citing FEIS Vol. 1, 3-326 to 3-350)) "By contrast, the Defendants estimate the timber industry supplies only 337 jobs, just one percent of regional employment, and $18.8 million, one percent of earnings, in the region today. Defendants project that, even with complete elimination of the Roadless Rule on the Tongass, the rule will not result in any new timber industry jobs on the Tongass over the next 100 years and regional economic impacts from the timber industry will remain the same with the Exemption as without. FEIS at 3-55." (Complaint para. 54, Organized Village of Kake v. Vilsack, No. 1:20-cv-00011 (D. Alaska, filed Dec. 23, 2020), p. 23 of 50 (plaintiffs characterizing the agency's own 2020 FEIS at 3-55)) "Large trees accounted for 2.0 to 3.7% of all stems (DBH ≥ 1" or 2.54 cm) among five tree species; but held 33 to 46% of the total AGC stored by each species. Pooled across the five dominant species, large trees accounted for 3% of the 636,520 trees occurring on the inventory plots but stored 42% of the total AGC." (Mildrexler, Berner, Law, Birdsey and Moomaw 2020, Front. For. Glob. Change 3:594274, abstract (AGC is aboveground carbon; the study covers the six eastside national forests)) 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 that it explain on the record 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 request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Andrew Scales Chattanooga, TN