Comment Analysis · Docket FS-2025-0001

FS-2025-0001-475743

Opposes rescissionPosted September 23, 2026 On Regulations.gov

Exact copy — Byte-identical to another submission. This comment stands for 2 submissions in its group.

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

  • Economic Impact Fiscal
    • “projected timber revenue does not adequately justify the potential public costs”
    • “potential losses of $6.1 million annually in economic benefits to recreationists”
    • “distinguish gross receipts from net fiscal returns”
    • “responsible economic policy”
  • Wildlife Habitat
    • “demonstrate the economic importance of healthy habitat”
    • “Wildlife and wild places also have intrinsic value beyond their commercial uses”
    • “responsibility extends to future generations and the habitats wildlife needs to survive”
    • “Protecting... wildlife”
  • Water Quality Quantity
    • “contribute 5.2 trillion gallons of surface water annually to public water supplies”
    • “estimated $47 billion in annual value associated with avoided treatment, dredging, and water-quality violation costs”
    • “watershed protection belongs in a complete economic assessment”
    • “Protecting clean water”
  • Recreation Tourism Public Use
    • “Americans spent $99.4 billion on recreational fishing and $45.2 billion on hunting”
    • “opportunity to hunt and experience quiet country away from roads”
    • “Development can diminish the very qualities that make a landscape worth visiting”
    • “outdoor traditions”

What it names

National Forests
Osceola National Forest
Roadless areas
Impassable BayWilderness Study Area

The comment

I am an environmental scientist and hunter living in Jacksonville, Florida. I strongly oppose fully or partially rescinding the 2001 Roadless Area Conservation Rule. I support smart development, small businesses, American manufacturing, and growth in American GDP. Those priorities require fiscal discipline and responsible stewardship. Rescinding roadless protections is short-sighted, and the projected timber revenue does not adequately justify the potential public costs. USDA estimates $5.2–$11.4 million in additional annual revenue to the Treasury and Forest Service, plus $4.6–$10.6 million to the timber industry. Yet the agency acknowledges that the harvest scenario underlying these estimates is unlikely to be fully realized because of budget, operational, and market constraints. The same proposal estimates potential losses of $6.1 million annually in economic benefits to recreationists—equivalent to approximately 54%–117% of the projected federal timber receipts. These are different economic measures, but their relative size demonstrates why timber revenue alone cannot establish a net public benefit. USDA also identifies a $6.9 billion deferred-maintenance backlog for roads and bridges. The projected additional annual federal timber revenue equals just 0.075%–0.165% of that backlog, before considering new obligations. Adding roads requires a credible accounting of construction, maintenance, erosion control, restoration, and eventual decommissioning costs—and an explanation of who will pay them. Hunting and fishing already support substantial economic activity. The U.S. Fish and Wildlife Service reports that Americans spent $99.4 billion on recreational fishing and $45.2 billion on hunting in 2022: $144.6 billion combined. Wildlife watching generated another $250.2 billion in expenditures. These nationwide figures are not attributable solely to roadless lands, but they demonstrate the economic importance of healthy habitat and quality outdoor experiences. Forests also provide services that never appear on a timber-sale receipt. Forest Service research estimates that national forests and grasslands contribute 5.2 trillion gallons of surface water annually to public water supplies, with an estimated $47 billion in annual value associated with avoided treatment, dredging, and water-quality violation costs. This system-wide estimate is not a forecast of losses from rescission. It shows why watershed protection belongs in a complete economic assessment. USDA should quantify the incremental risks to these benefits rather than treating benefits that are difficult to price as worth zero. It should also distinguish gross receipts from net fiscal returns and evaluate cumulative costs over the full life of any resulting development. This issue is personal. I routinely hunt and take pleasure in the Osceola National Forest, just west of Jacksonville. Forest Service inventory figures identify approximately 20,737 acres of inventoried roadless areas there, including Pinhook, Impassable Bay, and the Natural Area Wilderness Study Area. These places are part of the landscape I know and value. The opportunity to hunt and experience quiet country away from roads, vehicles, and heavy equipment cannot be fully captured by spending statistics. Access matters, but so does the character of the place being accessed. Development can diminish the very qualities that make a landscape worth visiting. If there is one thing America has no shortage of, it is roads. The Forest Service’s infrastructure assessments describe approximately 370,000 miles of them. We should maintain existing infrastructure while conserving places where Americans can still experience undeveloped country. Wildlife and wild places also have intrinsic value beyond their commercial uses. The North American Model of Wildlife Conservation recognizes wildlife as a public resource managed on behalf of all citizens. That responsibility extends to future generations and the habitats wildlife needs to survive. As Theodore Roosevelt stated: “I recognize the right and duty of this generation to develop and use the natural resources of our land; but I do not recognize the right to waste them, or to rob, by wasteful use, the generations that come after us.” Please retain the Roadless Rule and reject full or partial rescission that weakens its protections. Protecting clean water, wildlife, outdoor traditions, and our shared natural inheritance is sound stewardship and responsible economic policy.

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