Comment Analysis · Docket FS-2025-0001

FS-2025-0001-428302

Opposes rescissionA1 strongSubstance 13/24Owed an answerPosted September 16, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the Roadless Area Conservation Rule fails to adequately address legal deficiencies regarding state-specific frameworks, does not quantify administrative burdens outside existing exceptions, contains a defective Regulatory Flexibility Act certification that ignores specific economic impacts on small entities, and fails to weigh documented reliance interests including hunting traditions, specific acreage in Pennsylvania, and water intake dependencies.

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

Environmental Protection Biodiversity
- “wildlife and wild places have to be actively protected to survive”
- “extremely diverse and important part of the ecosystem”
- “keeps these places intact”
- “nationally significant roadless values”
Legal Regulatory Framework
- “Ninth Circuit struck it down”
- “Regulatory Flexibility Act certification in this proposal is also defective”
- “controlling administrative law”
- “agency reversing a longstanding policy must identify and genuinely weigh the reliance interests”
Water Quality Quantity
- “watershed integrity”
- “286 municipal water intakes across the Eastern region depend on”
Recreation Tourism Public Use
- “Hunting is tradition in my family”
- “Enjoying nature as a child taught me its value”
- “recreation benefits will be lost at a minimum of $6.1 million a year”

What it names

National Forests: Allegheny National Forest
Law cited: 36 C.F.R. Section 294.12

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 Hunting is tradition in my family, and it is also how I learned that wildlife and wild places have to be actively protected to survive. I hunt in Allegheny National Forest, which is an extremely diverse and important part of the ecosystem in Pennsylvania, and I am on the lookout for anything and everything when I am out there. Pennsylvania holds 7 inventoried roadless areas totaling 24,866 acres, and those acres are part of what makes Allegheny worth passing down. I think my nieces and nephews deserve to enjoy the same, or better, Earth that I did while growing up. Enjoying nature as a child taught me its value as a source of happiness, and I will not stay quiet while the agency proposes to undo the rule that keeps these places intact. The agency's stated rationale for rescission rests heavily on the claim that state-specific approaches can substitute for a single national rule. The record tells a different story. The last time the agency replaced the national Roadless Rule with a state-by-state framework, the Ninth Circuit struck it down precisely because local decision-making can incrementally erode nationally significant roadless values. The agency has not explained how this proposal avoids those same deficiencies, and I ask that it do so, specifically, before this proceeding closes. The proposal also justifies rescission on grounds of permitting and administrative burden, but the rule as written already contains exceptions for the situations the agency describes as problematic. The rule it proposes to eliminate states that It generally banned road building subject to limited exceptions including: the preservation of "reserved or outstanding rights" or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3). The agency has not identified which specific burdens fall outside these existing exceptions, including those covering existing mineral leases and community wildfire protection. It should quantify those burdens on the record, not assert them in the abstract. The Regulatory Flexibility Act certification in this proposal is also defective. The agency certifies no significant impact on small entities while simultaneously acknowledging in its own analysis that outfitters, guides, and tour operators operating in roadless areas will be affected and that recreation benefits will be lost at a minimum of $6.1 million a year. That certification is reached by spreading an expenditure loss across every small firm in the sector nationally rather than assessing the actual permit-holders operating in the affected areas. The agency concedes that some of those firms may lose these receipts entirely. The certification should be withdrawn, and the analysis should focus on the small entities who actually depend on the roadless character of places like Allegheny National Forest, not a diluted national average. 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. That is not a minor gap. Under controlling administrative law, an agency reversing a longstanding policy must identify and genuinely weigh the reliance interests its prior rule created, not invite them into the record and then ignore them. My family's hunting tradition, my expectation that 24,866 acres of Pennsylvania roadless land will remain intact for my nieces and nephews, and the watershed integrity that 286 municipal water intakes across the Eastern region depend on are all reliance interests this rescission threatens. The agency must treat what it receives in this comment period as what it is: evidence of reliance, not noise to be set aside. Sincerely, Audrey Hunter Canonsburg, Pennsylvania