Comment Analysis · Docket FS-2025-0001

FS-2025-0001-518993

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted September 30, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Area Conservation Rule conflicts with its own DEIS findings regarding wildfire ignition rates and elk survival, fails to analyze population-level effects on big game or hydrological impacts on specific watersheds in the Manti-La Sal, Superior, Monongahela, George Washington, and Chequamegon-Nicolet National Forests, and does not justify rescission by quantifying administrative burdens not already addressed by existing regulatory exceptions.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Wildlife Habitat
- “Elk are present there in part because of that absence”
- “elk survival rates increased during a road closure and decreased when the gates were removed”
- “The Hellbender salamander depends on pristine water quality and is at particular risk from road-induced sedimentation”
- “offer solitude and wildlife experience that are genuinely hard to find”
Water Quality Quantity
- “watched what happens to water quality when a road enters a watershed”
- “sedimentation goes up, and during large precipitation events the runoff can be significant”
- “Those unlogged ridges and intact soils are filtering some of the cleanest freshwater”
- “protect headwaters that feed the Potomac”
Recreation Tourism Public Use
- “sought that country precisely because of the absence of roads and vehicles”
- “allows hikers and backpack campers like me to move through primary forest in non-motorized solitude”
- “My son and I go into those forests specifically looking for reptiles and amphibians”
- “How does the agency intend to maintain non-motorized user experiences”
Forest Management Wildfire
- “Opening it to roads would most likely mean less elk and more wildfire”
- “A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “The proposal justifies rescission partly on wildfire and fuels management grounds”
- “reconcile this proposal with the ignition data in its own DEIS”

What it names

National Forests: George Washington National Forest Monongahela National Forest Superior National Forest
Roadless areas: Dolly Sods Roaring PlainSouthern Massanutten
Law cited: 36 C.F.R. Section 294.12
Works cited: Andrews et al. 2015

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Roadless backcountry is worth fighting for, and I am fighting for it here. I have hunted elk on the Horse Mountain and Mans Peak area of the Manti-La Sal National Forest in Utah, and I sought that country precisely because of the absence of roads and vehicles. Elk are present there in part because of that absence. Opening it to roads would most likely mean less elk and more wildfire. That last point is not my opinion alone; it is the agency's own finding, and the agency owes an answer for why it now proposes to walk away from it. The agency's record states: "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 proposal justifies rescission partly on wildfire and fuels management grounds. Those two positions cannot stand together without an explanation. I ask that the agency reconcile this proposal with the ignition data in its own DEIS, and explain plainly why it is departing from its own prior findings on fire occurrence in roadless areas. On elk specifically, the agency's record is just as clear: "The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." The agency projects no population-level effect on big game anywhere in its analysis. That is not a gap I am willing to accept. Utah holds 4,013,529 acres across 222 inventoried roadless areas, and the hunting opportunity that depends on those acres deserves a real answer. I ask that the agency project, on the record, the effects of rescission on big game populations and on hunter opportunity before it takes any final action. I have fished the Superior National Forest since I was a young boy growing up in northern Minnesota. I have watched what happens to water quality when a road enters a watershed, even when the work is done responsibly: sedimentation goes up, and during large precipitation events the runoff can be significant. The Superior holds 13 inventoried roadless areas totaling 62,004 acres that feed the Boundary Waters system. Those unlogged ridges and intact soils are filtering some of the cleanest freshwater in the lower 48 before it enters the lakes. My son and I go into those forests specifically looking for reptiles and amphibians. The Hellbender salamander depends on pristine water quality and is at particular risk from road-induced sedimentation. The roadless areas of the Superior are qualitatively different from the roaded portions, and I have seen that difference myself over a lifetime. The agency should explain what specific protections will replace the hydrological function currently provided by the rule. The Dolly Sods Roaring Plain roadless area in the Monongahela National Forest contributes to the intactness of that broader ecosystem and allows hikers and backpack campers like me to move through primary forest in non-motorized solitude. The Monongahela's 20 inventoried roadless areas total 174,885 acres and protect headwaters that feed the Potomac. The few roadless areas remaining in the George Washington National Forest, including Southern Massanutten, offer solitude and wildlife experience that are genuinely hard to find anywhere in the densely populated Eastern United States. The Flynn Lake Study Area in the Chequamegon-Nicolet is one of very few such places in that forest; if roads enter it, it will no longer be eligible for Wilderness designation. How does the agency intend to maintain non-motorized user experiences in any of these places once roads are in? Finally, the rule as written already allows construction necessary for public health and safety and preserves reserved or outstanding rights. See 36 C.F.R. Section 294.12(b)(1),(3). The agency has not identified which specific burdens are not already addressed by those exceptions. Rescinding the rule to relieve administrative burden is not a justification if the burden can be addressed within the rule's existing framework. The agency needs to quantify those burdens specifically and show why the exceptions are insufficient. The vast majority of the United States, including most of the National Forests, already has road access. Once a road is built, it is a permanent scar on the landscape, even if eventually closed. Roads don't belong everywhere. My son should inherit these places as they are. Sincerely, Matthew Steil Washington D.C.