Comment Analysis · Docket FS-2025-0001

FS-2025-0001-322743

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted September 7, 2026 On Regulations.gov

In short: The comment places on the record specific data from the agency's own DEIS and Cost Benefit Analysis regarding increased wildfire risk, sedimentation impacts on 378 water intakes, and $6.1 million in lost recreation benefits, while requesting the agency reconcile these findings with its justification for rescinding the Roadless Area Conservation Rule and weigh the commenter's reliance interests.

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

Water Quality Quantity
- “contamination of pristine waterways”
- “fight to save the Buffalo River”
- “378 municipal water intakes sit in watersheds containing affected roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment”
Recreation Tourism Public Use
- “untouched hiking spots, breathtaking overlooks”
- “the kind of silence that even rowdy Scout boys could feel”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “birdwatching, hiking, and photography that draw people to these forests”
Forest Management Wildfire
- “roads through forests are the number one cause of fire”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile that claimed justification with this ignition data”
- “dangers of new road construction”
Governance Policy Process
- “No one answered me or explained why the agency was moving in this direction”
- “The agency must identify and weigh the reliance interests”
- “The proposal solicits 'any reliance interests in the current rule'”
- “The case for punching new roads... has not been made”

What it names

National Forests: Ouachita National Forest Ozark-St. Francis National Forest
Roadless areas: Bear MountainLittle BlakelyPedestal Rocks

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Ozark and Ouachita mountains make Arkansas a beautiful state, and they are beautiful largely because the parks and forests have been so careful about where roads go. Those choices left lovely untouched hiking spots, breathtaking overlooks, and the kind of silence that even rowdy Scout boys could feel when I took a troop to Little Blakely, all 3,342 acres of it in the Ouachita National Forest. That peacefulness is not an accident. It is the product of rules like the one this administration now proposes to discard, and I oppose that rescission. I have filed public comments several times regarding the dismantling of the Forest Service and the dangers of new road construction. No one answered me or explained why the agency was moving in this direction. This letter is my attempt, again, to place my concerns where they must be addressed. Arkansas holds 15 inventoried roadless areas totaling 95,015 acres. Bear Mountain, 1,910 acres in the Ouachita National Forest, is among them. My neighbor has hiked there for years. When she comes home from those hikes she is renewed and refreshed, and I understand why: that kind of restoration is something we desperately need in this technological age. Pedestal Rocks, 21,957 acres in the Ozark-St. Francis National Forest, is another. In Arkansas we know that roads through forests are the number one cause of fire and contamination of pristine waterways. The agency's own record agrees. The DEIS 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 proposal nonetheless uses wildfire management as a justification for rescission. I ask that the agency reconcile that claimed justification with this ignition data and explain in its response why it is departing from findings already in its own draft environmental impact statement. The water issue is one I know from lived experience. We have had to fight to save the Buffalo River, the First National River, more than once. Back in the 1960s and again in the 2000s, a great deal of energy and money went into fighting hog farm runoff that was contaminating the river. I remember times when we could not swim because of the high bacteria count. The agency's own data shows that roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and that across the Southern region, which includes Arkansas, 378 municipal water intakes sit in watersheds containing affected roadless areas. Opening 95,015 acres of Arkansas roadless land to new roads puts those intakes and the people who depend on them at documented risk. I ask that the agency explain what specific finding supports its conclusion that this risk is acceptable. The agency's road maintenance backlog makes the proposal harder to defend, not easier. I am sick and tired of my tax dollars going to destroy our public lands. So much has already been cut that skeleton teams of rangers cannot keep up maintenance on the roads already there. The agency is already billions behind on its existing road system. The case for punching new roads into country that has none, when it cannot maintain what it has, has not been made, and the agency should be required to make it before proceeding. The supporting regulatory flexibility analysis certifies no significant impact on small entities while the DEIS identifies outfitters, guides, and tour operators as affected, and its own Cost Benefit Analysis records lost recreation benefit at a minimum of $6.1 million a year. The birdwatching, hiking, and photography that draw people to these forests, where someone hoping to spot a Red-Cockaded Woodpecker Finally, The proposal solicits "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 one such interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final rule issues. Sincerely, Margaret Cameron Little Rock, Arkansas