Comment Analysis · Docket FS-2025-0001

FS-2025-0001-495271

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted September 28, 2026 On Regulations.gov

In short: The comment documents that the agency's proposed rescission of the Roadless Area Conservation Rule fails to honestly cost new road construction against a $6.9 billion maintenance backlog, contradicts its own DEIS data showing higher human-caused fire rates on roaded lands, and improperly dilutes economic impacts on local outfitters through national averaging while ignoring specific reliance interests in areas like Boggs Creek.

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

Environmental Protection Biodiversity
- “black bear, brook trout, cerulean warbler, hellbender, and the northern long-eared bat persist precisely because some country has remained unroaded”
- “A logged stand grows back. A road does not.”
- “spend money to spoil our beautiful natural habitats”
- “Cohutta Wilderness and its surroundings represent the wildest land in the southeastern United States”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “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”
- “The fire rationale offered for rescission is in direct conflict with the agency's own data”
- “quantify the expected increase in human-caused ignitions that new road access into places like Boggs Creek would produce”
Recreation Tourism Public Use
- “The best years of my youth were spent camping and hiking in unspoiled forests”
- “I want my future children to have the same relationship with nature that I had”
- “books lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides and tour operators as affected”
Governance Policy Process
- “The Forest Service held more than 600 public meetings and received 1.6 million comments before it wrote the 2001 rule. It has held none to undo it.”
- “The regulatory flexibility analysis does not survive scrutiny either”
- “The agency should withdraw the certification and assess the operators actually working in the potentially affected roadless areas”
- “constitute exactly the reliance interests that binding precedent requires the agency to identify and assess”

What it names

National Forests: Chattahoochee National Forest
Roadless areas: Boggs Creek

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The best years of my youth were spent camping and hiking in unspoiled forests in Georgia. Boggs Creek, in the Chattahoochee National Forest, is not an abstraction to me. I grew up with one of the Boggses, a descendant of the family whose name that land carries. I have been there. I want my future children to have the same relationship with nature that I had, and I am writing because this proposal threatens to foreclose that possibility permanently. The Chattahoochee holds 23 inventoried roadless areas totaling 63,351 acres, including the 2,073-acre Boggs Creek area. These are not interchangeable parcels. The Cohutta Wilderness and its surroundings represent the wildest land in the southeastern United States, at the southern end of the Appalachian chain, where black bear, brook trout, cerulean warbler, hellbender, and the northern long-eared bat persist precisely because some country has remained unroaded. A logged stand grows back. A road does not. The Forest Service held more than 600 public meetings and received 1.6 million comments before it wrote the 2001 rule. It has held none to undo it. That asymmetry alone should give the agency pause. To me, it makes no sense to spend money to spoil our beautiful natural habitats, and the agency's own record reinforces that judgment. The Forest Service is already carrying a deferred maintenance backlog of $6.9 billion on roads it already has, against a road budget of roughly $73 million a year. Proposing to push new roads into country that has none, into places like Boggs Creek that carry both ecological and human history, while that deficit compounds, is a choice the agency has not honestly costed. It should explain why new road construction is a responsible expenditure when existing infrastructure is degrading at a rate the current budget cannot address. The fire rationale offered for rescission is in direct conflict with the agency's own data. The DEIS states that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The same record documents 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." The agency must quantify the expected increase in human-caused ignitions that new road access into places like Boggs Creek would produce and weigh that figure honestly against any claimed reduction in wildfire hazard, because the data it has already assembled cuts sharply against the direction it is moving. The regulatory flexibility analysis does not survive scrutiny either. "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." That certification is reached by averaging the projected expenditure loss across every small firm in the sector nationally, rather than assessing the guides and outfitters who actually hold permits in the affected areas. The agency concedes that some of those firms may lose those receipts entirely. Spreading impact across an industry to dilute it is not analysis. The agency should withdraw the certification and assess the operators actually working in the potentially affected roadless areas, not a national composite. Finally, this comment is itself the kind of reliance interest the agency invited and then declined to weigh. "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." Decades of people growing up in and around places like Boggs Creek, building lives and families around the expectation that these areas would remain protected, constitute exactly the reliance interests that binding precedent requires the agency to identify and assess when it changes course. The agency should treat the comments it receives, including this one, as evidence of those interests and address them with the seriousness the law requires. Sincerely, Chukwudubem Egbuniwe Los Angeles, CA