Comment Analysis · Docket FS-2025-0001

FS-2025-0001-357922

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment documents that the agency's economic analysis fails to establish a net benefit for the rule rescission, citing a $6.9 billion road maintenance backlog and negative net present value scenarios, while highlighting the public health risk to 7,000 municipal water intakes and supporting the No Action alternative.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Analytical gap, Evidence.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Recreation Tourism Public Use
- “hiking in Shenandoah with my family”
- “canoe camping in the Boundary Waters”
- “recreation losses of at least $6.1 million a year”
- “hike and camp and find themselves”
Water Quality Quantity
- “clean water”
- “unlogged ridges filter rain through intact forest soils”
- “deliver some of the cleanest freshwater in the lower 48”
- “7,000 municipal water intakes sit in watersheds fed by roadless areas”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent”
- “projects $5.2 to $11.4 million a year in timber revenue”
- “net present value spanning -$92 million to +$199 million”
- “existing road system already carries a $6.9 billion maintenance backlog”

What it names

National Forests: Ozark-St. Francis National Forest Shawnee National Forest Superior National Forest

The comment

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

The Roadless Area Conservation Rule has shaped my life in ways I only fully appreciate now that it is under threat. I grew up in Virginia hiking in Shenandoah with my family, and I carried that into adulthood: climbing outdoors for the first time (and many subsequent times) in Shawnee National Forest, canoe camping in the Boundary Waters, camping in Ozark-St. Francis National Forest during spring break... Many of my happiest memories were made possible by the 2001 rule. That is part of why I oppose its rescission. Beyond recreation, there are serious public health concerns posed by the repeal of this rule, namely clean water. The Superior National Forest holds 13 inventoried roadless areas totaling 62,004 acres feeding the Boundary Waters, where I canoe camped. Those unlogged ridges filter rain through intact forest soils and deliver some of the cleanest freshwater in the lower 48 into that lake system. Across the country, more than 7,000 municipal water intakes sit in watersheds fed by roadless areas. In a time when cities are already struggling to maintain clean drinking water for their residents, can we really afford to risk that? Furthermore, the agency's own economic record cannot make the case for this action. The proposal's supporting materials state 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 that baseline, the agency's Cost Benefit Analysis 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, with a net present value spanning -$92 million to +$199 million, all while the existing road system already carries a $6.9 billion maintenance backlog. I ask that the agency reconcile the proposal with those figures and explain how an action whose own analysis cannot establish a net benefit justifies expanding a road network it already cannot afford to maintain. The concept of connecting with undeveloped land has occupied Americans since before this nation's founding, and it has played an integral part in shaping who I am. It would be a shame if my children were not able to experience that as well, to hike and camp and find themselves through getting lost. For all these reasons I support Alternative 1, the No Action alternative.