Comment Analysis · Docket FS-2025-0001

FS-2025-0001-529766

Opposes rescissionA1 strongSubstance 18/24Owed an answerPosted October 1, 2026 On Regulations.gov

In short: The comment documents that the agency's proposed rescission fails to quantify specific permitting burdens not addressed by existing exceptions, ignores reliance interests and municipal water intake data, and contradicts its own DEIS data regarding human-caused wildfire ignition densities in roadless areas.

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

  • Recreation Tourism Public Use
    • “Hiking and camping is one of the most important and meaningful ways my family and I connect”
    • “It disturbs me to my core to think this forest could be stripped of its wilderness”
    • “To spend time in the presence of roadless wilderness is one of the most awe-inspiring human experiences”
  • Wildlife Habitat
    • “habitats of living creatures paved over”
    • “The Monongahela shelters the West Virginia northern flying squirrel, the Cheat Mountain salamander”
    • “Road access will not leave any of this intact”
  • Water Quality Quantity
    • “protect headwaters that feed the Potomac and eventually the drinking water of Washington, D.C.”
    • “polluted with runoff from roads”
    • “286 municipal water intakes sit in watersheds containing affected roadless areas”
  • 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”
    • “The agency claims new road access will reduce wildfire hazard. Its own numbers say the opposite”
    • “I ask that the agency quantify the expected increase in human-caused ignitions from new road access”

What it names

National Forests
Monongahela National Forest
Roadless areas
Cheat MountainDolly Sods Roaring PlainSeneca Creek
Law cited
36 C.F.R. Section 294.12

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking and camping is one of the most important and meaningful ways my family and I connect to each other, decompress from the stresses of life, and find joy in living. Places like Seneca Creek and the Dolly Sods Roaring Plain in the Monongahela National Forest are within driving distance of our home in Maryland. It is a place my family has been and a forest I look forward to further exploring with my family. It disturbs me to my core to think this forest could be stripped of its wilderness, chopped down, habitats of living creatures paved over, polluted with runoff from roads, and the dark starry night skies blotted out with light pollution. This land belongs to the people of the United States, and I say this is NOT what I want done to my land. These places give my life meaning. They give my family connection. To spend time in the presence of roadless wilderness is one of the most awe-inspiring human experiences. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. I ask that it be entered and addressed in full on the record. The Monongahela's 20 inventoried roadless areas total 174,885 acres and protect headwaters that feed the Potomac and eventually the drinking water of Washington, D.C. Seneca Creek alone covers 22,287 acres. The Dolly Sods Roaring Plain covers 13,392 acres. These are not abstract statistics. They are the places where my family breathes. The ecosystems at Dolly Sods are spruce-bog remnants more reminiscent of northern Canada than West Virginia, relics of the last ice age clinging to the highest ridges. The Monongahela shelters the West Virginia northern flying squirrel, the Cheat Mountain salamander, the snowshoe hare, the northern long-eared bat, and the red spruce. Road access will not leave any of this intact. It will open these irreplaceable places to being gutted by logging industries and other industrial uses. Why should my generation and the next be robbed of the very few remaining intact forests left in this country? The agency says the rule's permitting burden justifies rescission. But the rule already provides for what the agency claims it cannot do. It generally banned road building subject to limited exceptions including: the preservation of "reserved or outstanding rights" or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3). The agency has not shown which specific burdens those existing exceptions fail to address. I ask that the agency identify which specific burdens are not already addressed by the rule's existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and that it quantify those burdens with specificity. Across the Eastern region, which includes West Virginia, 286 municipal water intakes sit in watersheds containing affected roadless areas. West Virginia alone holds 25 inventoried roadless areas totaling 195,455 acres. My family, driving from Maryland to reach these forests, is among the users whose reasonable expectations were shaped by two decades of the rule's protections. 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. That is not a procedural footnote. It is a legal deficiency. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further. Finally, the agency's own fire data undermines a core justification for rescission. 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 claims new road access will reduce wildfire hazard. Its own numbers say the opposite. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it honestly against any claimed reduction in wildfire risk before this proposal advances another step. Keep the Roadless Rule. Protect Seneca Creek, the Dolly Sods Roaring Plain, and the Monongahela National Forest. Let all 58.3 million acres of wild National Forests remain intact, wild, beautiful, and the absolute American priceless treasure that they are to all living creatures. Sincerely, Rachel Smith Baltimore, Maryland

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