Comment Analysis · Docket FS-2025-0001

FS-2025-0001-456702

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted September 21, 2026 On Regulations.gov

In short: The comment establishes that the agency's analysis of recreation costs is flawed by scoping them to operable acreage rather than the road-access footprint, fails to analyze displacement effects and the inadequacy of the 2004 land management plan as a safeguard, and requests the selection of the No Action alternative or a retention alternative for forests with small roadless acreage shares.

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, Alternative.

Standard dismissals it defeats

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.

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.
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
- “camped and backpacked in the Chattahoochee National Forest”
- “recreation cost estimate is scoped to the wrong acreage”
- “concentrated use produces sanitation damage, litter, streambank degradation and user conflict”
- “reduces the low-cost, self-directed access the rule claims to expand”
Governance Policy Process
- “The central assurance that land management plans will govern is unsupported”
- “The governing plan... has never been applied to an actual road proposal”
- “Rescission does not return the decision to a plan that made it”
- “The Department has not demonstrated that replacing a nationwide standard with no nationwide standard is necessary”
Legal Regulatory Framework
- “ask the Department to select the No Action alternative”
- “The final EIS should re-estimate recreation effects”
- “The final EIS should identify, by unit, which plan components would actually constrain road construction”
- “explain why amending the existing rule... could not address the local flexibility concerns”

What it names

National Forests: Chattahoochee National Forest

The comment

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

I am a Georgia resident who has camped and backpacked in the Chattahoochee National Forest. I oppose the rescission and ask the Department to select the No Action alternative. My comment concerns three defects in the analysis. The recreation cost estimate is scoped to the wrong acreage. The rule states that losses to recreationists are "most likely to be associated with the operable areas of current IRAs," estimated at roughly $6.1 million per year. Operable acreage is the correct unit for estimating timber output. It is the wrong unit for recreation. The rule's own figures show why: it puts operable acreage at about 4.8 million acres, but acreage where new permanent roads could be added at about 18.2 million acres. Roads, not harvest units, change a recreation setting. A road at the edge of a roadless area alters what a visitor hears and sees well beyond the cut and redistributes use across every access point it opens. Scoping recreation costs to operable acreage measures them against roughly a quarter of the ground the agency says roads could reach. The benefit side is not scoped the same way. Timber revenue is presented as $5.2 to $11.4 million per year to the Treasury and Forest Service, plus $4.6 to $10.6 million to industry, under a full-realization scenario the Department itself calls unlikely. The analysis compares an optimistic ceiling on benefits against a narrowly bounded floor on costs. The final EIS should re-estimate recreation effects on the road-access footprint rather than operable acreage, and disclose how the $6.1 million figure changes. If a broader footprint was in fact used, the record should say so; the preamble reads otherwise. Reasonably foreseeable displacement effects are not analyzed. The rule states that developed and road-based recreation "could expand" and treats this as a benefit. It does not analyze whether that expansion adds recreation capacity or merely redistributes existing demand. On a forest within roughly two hours of the Atlanta metropolitan area, that distinction is decisive. The sequence is foreseeable, not speculative. New road access concentrates dispersed camping and day use; concentrated use produces sanitation damage, litter, streambank degradation and user conflict; and the agency's responses are site hardening, designated-site systems, fees, permits, concessionaire operation and closure. Each reduces the low-cost, self-directed access the rule claims to expand, and each carries recurring cost chargeable against the $6.9 billion deferred maintenance backlog the rule itself cites. The final EIS should analyze whether projected increases in road-based recreation are new or displaced demand, what managing concentrated dispersed use costs, and whether those costs are recovered through fees, permits or concession contracts. The central assurance that land management plans will govern is unsupported. The rule states that management direction "would continue to be governed by the applicable land management plans." It also states that it "does not require or compel the amendment or revision of any land management plan." The governing plan for the Chattahoochee-Oconee National Forests was signed in January 2004. As the agency has stated in this docket, the 2001 Rule's provisions supersede plan components for inventoried roadless areas. The plan direction now relied upon has therefore been inoperative for these acres for twenty-five years and has never been applied to an actual road proposal. Rescission does not return the decision to a plan that made it; it removes the only operative determination and substitutes a twenty-two-year-old plan no one is required to revisit. The Forest Service has also stated that monitoring since 2004 consistently shows the Chattahoochee is not adequately meeting that plan's goals and objectives. The Department cannot rely on that plan as an adequate safeguard here while describing it as underperforming elsewhere. The final EIS should identify, by unit, which plan components would actually constrain road construction in inventoried roadless areas upon rescission, and when each was last revised. Requested action. Select the No Action alternative. At minimum, the final EIS should analyze a retention alternative preserving the prohibition on units where inventoried roadless areas are a small share of total acreage, such as the Chattahoochee-Oconee at roughly 63,000 of about 867,000 acres, where the flexibility gained is smallest and the proportional loss greatest. No such alternative appears analyzed. The record should also explain why amending the existing rule, or a region-specific rule like those in effect for Idaho and Colorado under Subparts C and D, could not address the local flexibility concerns identified. Absent that explanation, the Department has not demonstrated that replacing a nationwide standard with no nationwide standard is necessary.