Comment Analysis · Docket FS-2025-0001

FS-2025-0001-517422

Opposes rescissionA2 moderateSubstance 16/24Owed an answerPosted September 30, 2026 On Regulations.gov

In short: The comment documents that the agency's record fails to support the rescission of the Roadless Area Conservation Rule because it relies on national averages for small entity impacts, ignores specific reliance interests, and fails to quantify the increased human-caused wildfire risk from new road access in the George Washington National Forest.

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
- “Appalachian Trail runs through some of the most demanding and rewarding terrain”
- “I hike these places for clean air and wildlife spotting”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “My decision to hike Three Ridges, the Priest, and Elliott Knob is inseparable from the expectation that these areas remain in the condition the rule has maintained”
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 from new road access”
Governance Policy Process
- “the record the agency has assembled does not support the action it is proposing”
- “regulatory flexibility analysis reaches a no-significant-impact conclusion by spreading losses across every small firm in the sector nationally”
- “The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal'... and the Cost Benefit Analysis weighs none”
- “I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas”
Water Quality Quantity
- “378 municipal water intakes sit in watersheds containing affected roadless areas”
- “fire risk in these landscapes a concern that extends far beyond the trailhead”

What it names

National Forests: George Washington National Forest
Roadless areas: Elliott KnobThe PriestThree Ridges

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 Appalachian Trail runs through some of the most demanding and rewarding terrain in Virginia, and Three Ridges and the Priest, both in the George Washington National Forest, are part of what makes that corridor worth protecting. Three Ridges is a difficult and important section of the AT, worth every bit of the effort because it leads to the Priest, which is itself a very difficult and beautiful hike. Elliott Knob, also in the George Washington, has gorgeous views that are not marred by roads. I hike these places for clean air and wildlife spotting. I am filing this comment in opposition to the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) because the record the agency has assembled does not support the action it is proposing. Virginia holds 64 inventoried roadless areas totaling 393,682 acres. The three areas I named sit inside that inventory, and the activities I described, hiking the AT for clean air and wildlife, depend directly on what the rule protects. The agency acknowledges that outfitters, guides, and tour operators are among the affected small entities, yet its regulatory flexibility analysis reaches a no-significant-impact conclusion by spreading losses across every small firm in the sector nationally rather than examining the firms that actually hold permits in the affected areas. The DEIS itself books lost recreation benefit at a minimum of $6.1 million a year, and the supporting analysis concedes that some firms may lose those receipts entirely. The agency's own text states: "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 cannot stand beside that analysis. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. The proposal also solicits reliance interests and then does nothing with them. The agency's own language reads: "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." My decision to hike Three Ridges, the Priest, and Elliott Knob is inseparable from the expectation that these areas remain in the condition the rule has maintained. When an agency changes course, it must reckon with what its prior policy created. This comment is one such interest, and it is not the only one. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Finally, the agency's own fire data argues against what the proposal implies. The record states: "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." Elliott Knob's views are unmarred by roads, and the data show that this matters well beyond aesthetics. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing affected roadless areas, making fire risk in these landscapes a concern that extends far beyond the trailhead. The effects analysis itself concedes that road access could increase the number and frequency of wildfires, yet the proposal frames new access as a fire-management benefit without quantifying the offsetting cost. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard before this record can support any final action.