Comment Analysis · Docket FS-2025-0001

FS-2025-0001-536235

Opposes rescissionA1 strongSubstance 19/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment establishes that the agency's record contains internal inconsistencies regarding economic net benefits and maintenance costs, fails to apply cited biodiversity fragmentation data to the 40.1 million acres affected, and lacks population-level projections for elk impacts, thereby documenting specific analytical gaps in the rescission proposal.

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 survival rates increased during a road closure”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “value of the animals it holds”
- “uncontrolled damage is irreversible”
Economic Impact Fiscal
- “net present value range spanning -$92 million to +$199 million”
- “existing road system already carries a $6.9 billion maintenance backlog”
- “timber revenue to the Forest Service of $5.2 to $11.4 million a year”
- “recreation losses of at least $6.1 million a year”
Recreation Tourism Public Use
- “I walk and hike in places near my house”
- “My family has fished for generations”
- “I hunt and fish because I believe in the value of the animals”
- “recreation losses of at least $6.1 million a year”
Governance Policy Process
- “The agency has not squared its proposal with its own numbers”
- “The agency should identify, by specific category, which burdens are not already addressed”
- “The agency must project those effects before it acts”
- “The agency must apply that cited fragmentation range to the full 40.1 million acres”

What it names

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 placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Everywhere and everyone deserves to have safe access in their backyard. That belief is why I oppose the rescission of the 2001 Roadless Area Conservation Rule. The land is a teaching tool. That is how I think about it: using it well, understanding the value of the animals it holds, and making sure it lives long into the future. My family has fished for generations. There are ups and downs sometimes, but uncontrolled damage is irreversible, and that distinction matters. I walk and hike in places near my house, and even after living here for years there is still so much I have not seen. What is at stake here is not abstract. It is the kind of country that rewards patience and teaches people to care. The agency has not squared its proposal with its own numbers. The record states 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 figures do not describe a resource emergency. The agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, and a net present value range spanning -$92 million to +$199 million. The existing road system already carries a $6.9 billion maintenance backlog. I ask that the agency reconcile this proposal with those figures and explain how an action whose own analysis cannot establish a net benefit justifies expanding a road network the agency cannot afford to maintain. The agency frames this rescission partly as a permitting and administrative burden argument. But the rule already accommodates the activities most often cited. 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 should identify, by specific category, which burdens are not already addressed by these existing exceptions, including those covering existing mineral leases and community wildfire protection, and it should quantify those burdens with evidence rather than assertion. I hunt and fish because I believe in the value of the animals and in leaving something intact. The agency's own document acknowledges what roads do to that. The DEIS states 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." That finding appears in the agency's record and then stops there. No population-level projection follows. No estimate of what opening roadless areas means for elk numbers or hunter opportunity appears anywhere in the document. The agency must project those effects before it acts. The DEIS acknowledges that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is cited and then set aside. It is never applied to the 40.1 million acres of potentially affected environment that this rescission puts in play. A number that wide, across an area that large, is not a footnote. It is the central question. The agency must apply that cited fragmentation range to the full 40.1 million acres and show what the consequences actually look like before this rule is eliminated. Uncontrolled damage is irreversible. The agency has not shown that the benefits of rescission outweigh that fact. I ask that it answer each of these points in the record and reconsider this action. Sincerely, A concerned citizen