Comment Analysis · Docket FS-2025-0001

FS-2025-0001-343700

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

In short: The comment establishes that the agency's analysis fails to quantify carbon sequestration impacts under expanded harvest scenarios, ignores the procedural contradiction of deferring foreseeable plan amendments while soliciting comment on them, lacks an explanation for reversing the 2001 finding on local planning adequacy, and fails to quantify the increase in human-caused ignitions associated with new road access.

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

Climate Carbon Storage
- “not the carbon”
- “stored forest carbon in the coterminous United States”
- “quantify what happens to stored carbon and sequestration rates”
- “carbon sequestration will continue without providing any analysis”
Forest Management Wildfire
- “lived through fire seasons that were terrible and scary”
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land”
- “roads bring ignitions, and ignitions bring exactly the kind of fire seasons I have described”
- “quantify the expected increase in human-caused ignitions”
Governance Policy Process
- “procedural problem that compounds the carbon gap”
- “The agency cannot simultaneously declare the foreseeable consequences of this action out of scope and ask the public to comment on them”
- “reversing its own prior factual conclusion”
- “undone without a single public meeting held”
Wildlife Habitat
- “silence that keeps animals from being pushed into towns”
- “animals are stressed out of their habitat and into towns”
- “animals that live in these areas deserve the analysis”
- “old-growth, untouched state”

What it names

Law cited: 66 FR 3244

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 wildness my kid should be able to explore and see in its old-growth, untouched state is what this comment is really about. I paddle rivers and lakes, I have lived through fire seasons that were terrible and scary and hard to breathe through, and I am filing this comment because rescinding the 2001 Roadless Area Conservation Rule would damage things that cannot be put back: not the water, not the carbon, not the silence that keeps animals from being pushed into towns. The agency's own effects document states that these inventoried roadless areas contain a significant share of the nation's stored carbon: "The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons." The document then concludes that carbon sequestration will continue without providing any analysis of what happens to that figure when timber harvest and roading are authorized under subsequent plan amendments. That is not analysis; it is an assertion dressed as a conclusion. I ask the agency to quantify what happens to stored carbon and sequestration rates under each alternative, including scenarios in which harvest and road construction expand. The question of those plan amendments is itself a procedural problem that compounds the carbon gap. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). The agency cannot simultaneously declare the foreseeable consequences of this action out of scope and ask the public to comment on them. The analysis of expanded timber harvest area belongs inside this action, not deferred to future proceedings where the structural protection will already be gone. I ask the agency to treat the foreseeable plan-amendment scenario as part of this rulemaking and to analyze it accordingly. The agency also owes the public an explanation for reversing its own prior factual conclusion. The proposal asserts that local land management planning now adequately protects roadless values; in adopting the 2001 rule (66 FR 3244) the agency found the opposite, that local planning had allowed those values to be reduced piece by piece and that their national significance required a national rule. An agency is entitled to change course, but it must explain what changed and why the prior finding no longer holds. The proposal does not do that. It substitutes the assertion for the reasoning. I ask the agency to identify the specific evidence that supports reversing the 2001 finding and to engage directly with its own prior conclusion rather than simply displacing it. On fire, the agency's own data argue against this proposal in terms the agency does not adequately confront. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. I have seen fire seasons. I know what it means when animals are stressed out of their habitat and into towns, when the air becomes hard to breathe, when the landscape that is supposed to be left alone is instead destabilized. The agency's own numbers show that roads bring ignitions, and ignitions bring exactly the kind of fire seasons I have described. The effects analysis does not quantify the expected increase in human-caused ignitions that would follow from new road access, nor does it weigh that increase against whatever wildfire-hazard reduction the proposal claims. The agency must do that work before this rule moves forward. Without these places, we lose something that defines the United States. A road does not grow back. The rule that took more than 600 public meetings and 1.6 million comments to build is being undone without a single public meeting held. The waters I paddle, the old-growth wildness I want my kid to see, and the animals that live in these areas deserve the analysis this proposal has skipped. I oppose rescission and ask the agency to address each of these failures in the record. Sincerely, Emma Kottenstette Hotchkiss, CO 81419