Comment Analysis · Docket FS-2025-0001

FS-2025-0001-482179

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted September 25, 2026 On Regulations.gov

In short: The comment documents that the agency's record contains internal contradictions regarding economic benefits versus costs, fails to properly assess impacts on small entities, ignores solicited reliance interests, and lacks quantification of increased human-caused wildfire ignitions from road access.

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

Recreation Tourism Public Use
- “pristine landscape untouched by human activity”
- “recreation losses of at least $6.1 million a year”
- “outfitters, guides and tour operators as affected”
- “expecting to find country that has not been opened to mechanized extraction”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
- “quantify the expected increase in human-caused ignitions that road access brings”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “timber revenue of $5.2 to $11.4 million a year to the Forest Service”
- “net present value range spanning negative $92 million to positive $199 million”
- “road system already carries a $6.9 billion maintenance backlog”
Governance Policy Process
- “regulatory flexibility certification compounds the problem”
- “agency changing course must identify and weigh the reliance interests its prior policy created”
- “The agency must now do what it promised and actually weigh the interests it solicited”
- “Reaching a no-impact conclusion by averaging losses across every small firm in the sector nationally”

What it names

National Forests: Boise National Forest

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 The Boise National Forest is where I go to find what I can only describe as the pristine landscape untouched by human activity. I hike there, I camp there, and I keep my eyes open for any and all critters that come into view. The photographs I take are of a place that looks the way it does precisely because roads have not been pushed through it. The rescission of the 2001 Roadless Area Conservation Rule would end that, and the agency's own documents give me no confidence that it has weighed what it would be giving up. The proposal frames rescission partly in terms of timber and energy economics, yet the record the agency assembled says 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." Those are not figures I computed; they come from the agency itself. Against that marginal production gain, the agency's own cost-benefit work projects timber revenue of $5.2 to $11.4 million a year to the Forest Service, recreation losses of at least $6.1 million a year, and a net present value range spanning negative $92 million to positive $199 million, all while the road system already carries a $6.9 billion maintenance backlog. I ask that the agency reconcile its stated economic rationale with those numbers, and explain how opening more roads to produce less than half a percent of national timber volume makes financial sense when its own analysis cannot establish a net benefit. The regulatory flexibility certification compounds the problem. "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." Reaching a no-impact conclusion by averaging losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas, is not an assessment of the entities at risk. The agency should withdraw that certification and conduct a genuine analysis of the small businesses operating specifically inside the potentially affected roadless areas. I rely on the current rule every time I enter the Boise National Forest expecting to find country that has not been opened to mechanized extraction. That reliance is exactly what the agency invites comment on, and then declines to count. "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 settled administrative law, an agency changing course must identify and weigh the reliance interests its prior policy created. This comment is one such interest. The agency must now do what it promised and actually weigh the interests it solicited, including the one expressed here. Finally, the fire analysis cuts against the proposal more sharply than the agency acknowledges. Its own effects document states that "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." That is a ratio of more than seven to one. The same document concedes that road access could increase the number and frequency of wildfires. The critters I watch and the landscapes I photograph in the Boise National Forest are already subject to fire pressure. Before the agency claims that new roads reduce wildfire hazard, it must quantify the expected increase in human-caused ignitions that road access brings and place that number alongside whatever suppression benefit it is claiming. It has not done that, and it must. Sincerely, Concerned citizen Boise, Idaho