Comment Analysis · Docket FS-2025-0001

FS-2025-0001-539571

Opposes rescissionA0 noneSubstance 9/24Posted October 4, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's economic analysis regarding the rescission of the Roadless Area Conservation Rule, specifically highlighting the lack of net benefit, the failure to assess impacts on local small businesses in Dixie National Forest (Bunker Creek and Lava Beds), and the unaddressed reliance interests of the public.

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

A0 none: Counted, not answered.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Recreation Tourism Public Use
- “Taking all eight of our grandchildren into Dixie National Forest”
- “watching them discover their connection to the Earth”
- “booking recreation losses at a minimum of $6.1 million a year”
- “outfitters, guides, and tour operators as affected parties”
Economic Impact Fiscal
- “Cost Benefit Analysis cannot establish a net benefit”
- “timber revenues that may never materialize”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”
- “Development activities in inventoried roadless areas often cost more to plan and implement”
Environmental Protection Biodiversity
- “Bunker Creek... and the Lava Beds area... are the kind of undisturbed places the 2001 rule was written to protect”
- “A road through the Lava Beds would ruin the natural flow of rocks and color”
- “destroy the balance in what I can only call a very special environment”
- “found the undisturbed nature of our surroundings to be the whole point”
Water Quality Quantity
- “1,466 municipal water intakes sit in watersheds containing affected roadless areas”
- “The agency has not explained how opening these lands serves the public that depends on them”

What it names

National Forests: Dixie National Forest
Roadless areas: Beaver LakeBunker CreekLava BedsLava Beds

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Taking all eight of our grandchildren into Dixie National Forest, pointing out the firs, the aspens, the scat on the trail, the wide vistas from the high ridges, and watching them discover their connection to the Earth: that is what roadless protection made possible. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this letter be entered into Docket FS-2025-0001. The strongest argument against rescission is the agency's own numbers. The Cost Benefit Analysis cannot establish a net benefit from this action, projecting a net present value ranging from negative to positive across its own scenarios, while booking recreation losses at a minimum of $6.1 million a year against timber revenues that may never materialize. The record on the Tongass makes the pattern clear: "By contrast, the Defendants estimate the timber industry supplies only 337 jobs, just one percent of regional employment, and $18.8 million, one percent of earnings, in the region today. Defendants project that, the rule will not result in any new timber industry jobs on the Tongass over the next 100 yrs and regional economic impacts from the timber industry will remain the same with the Exemption as without. FEIS at 3-55." I ask that the agency reconcile this proposal with that economic record, that it explain how an action producing no projected employment gain justifies expanding a road system already carrying a $6.9 billion maintenance backlog, and that it answer this question plainly on the record. Bunker Creek, at 7,474 acres within Dixie National Forest, and the Lava Beds area, at 14,944 acres in the same forest, are the kind of undisturbed places the 2001 rule was written to protect. Our grandchildren adored the ancient lava beds and what the geology of that landscape could teach them. A road through the Lava Beds would ruin the natural flow of rocks and color. Permanent roads into Bunker Creek and the extractive industry access that would follow would destroy the balance in what I can only call a very special environment. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres, and across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The agency has not explained how opening these lands serves the public that depends on them. The agency's own record is candid about the economics: "Development activities in inventoried roadless areas often cost more to plan and implement than on other National Forest System lands. Some planned timber sales in inventoried roadless areas are likely to cost more to prepare and sell than they realize in revenues received. Because of the level of public controversy and analytical complexity, projects in roadless areas often require development of costly environmental impact statements for most resource development activities, including timber harvesting, in inventoried roadless areas. In some cases, road construction costs are higher due to rugged terrain or sensitive ecological factors. Many development projects in inventoried roadless areas are appealed or litigated." I ask that the agency identify which specific permitting burdens are not already addressed by the rule's existing exceptions for public health and safety, existing mineral leases, and community wildfire protection, and that it quantify those remaining burdens with specificity. We looked for beaver ponds and small wildlife in the beaver lake area and found the undisturbed nature of our surroundings to be the whole point. Our public lands belong to all Americans and all generations, not to a single administration's revenue calculus. The small-business certification attached to this proposal contradicts what the analysis beside it concedes: the DEIS names outfitters, guides, and tour operators as affected parties, and the Cost Benefit Analysis itself books lost recreation benefit at a minimum of $6.1 million a year. Spreading that loss across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas is not analysis. The agency must withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. These roadless areas, identified in 2001, should be kept intact for generations to come. 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. Families like mine planned around this protection. Teaching our grandchildren about firs, aspens, beaver ponds, and ancient lava geology was possible because the rule held. That reliance is real, it is documented in comments like this one, and the agency is required to identify and weigh it before changing course. Sincerely, Judy Kirshner, Los Angeles,CA