Comment Analysis · Docket FS-2025-0001

FS-2025-0001-352601

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal contains internal contradictions regarding wildfire risk and economic benefits, fails to properly assess small business impacts on specific outfitters, and ignores solicited reliance interests, thereby establishing a record of analytical deficiencies in the rescission of the Roadless Area Conservation Rule.

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
- “rivers I fish have already shown me what roads and logging do to water”
- “carry more dirt and sediment than they once did”
- “Tree lines that sheltered deep pools are gone”
Recreation Tourism Public Use
- “solitude, the exploration, and the feeling of being free in nature”
- “ride my mountain bike... on the trails that roadless protections have kept intact”
- “recreation losses of at least $6.1 million a year”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the rescission with the ignition data in its own DEIS Table 21”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value ranging from -$92 million to +$199 million”
- “Forest Service is also carrying a $6.9 billion maintenance backlog”

What it names

National Forests: Bighorn National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The rivers I fish have already shown me what roads and logging do to water. I have watched the Bighorn River, the Yellowstone, and the smaller rivers threaded throughout the West carry more dirt and sediment than they once did. Tree lines that sheltered deep pools are gone. Those pools are changed. I have seen it. I am opposing the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, because I fish those waters, I pack my truck each spring and summer for the solitude, the exploration, and the feeling of being free in nature, and I ride my mountain bike from Colorado and Utah to the Pacific Northwest, through Wyoming and Idaho, on the trails that roadless protections have kept intact. The Bighorn National Forest sits inside that geography. The agency's own record, and the logic of what I have seen on the water, demand a full accounting before this rule is erased. On fire, the agency cannot have it both ways. The proposal invokes wildfire and fuels management as a justification for opening roadless areas to roads. But the agency's own findings state: "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." I want the agency to explain, with specificity, why the proposal departs from that finding, and to reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for this rescission is not a case at all. The agency's own record acknowledges 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 trivial extraction gains, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million, a spread so wide it cannot establish a net benefit. The Forest Service is also carrying a $6.9 billion maintenance backlog on its existing road system. How does the agency justify expanding that system when its own numbers cannot confirm the action pays? I ask that the agency answer that question in the record. The small-business certification attached to this proposal is contradicted by the analysis sitting beside it. 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. The outfitters and guides who hold permits in the affected areas, including those operating near the Bighorn, are not the national average firm; spreading a $9 million annual expenditure loss across every small firm in the sector nationally is not an assessment of the people actually at risk. The agency must withdraw the certification and evaluate the businesses that actually hold permits in the potentially affected roadless areas. The agency's own solicitation makes this comment legally relevant in a second way. 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. Under the principles that govern agency course changes, reliance interests created by a prior policy must be identified and weighed before that policy is abandoned. My use of these areas, the rivers I return to, the trails my bike takes me across, and the big-game habitat that roadless protections have maintained for sheep and other wildlife in forests like the Bighorn, all of it constitutes exactly the kind of reliance the agency asked about and then ignored. The agency built Alternative 3 because commenters asked to protect big-game habitat, fisheries, and wildlife connectivity, then chose the alternative that protects none of it. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. Sincerely, Jessica Worley Portland, OR