Comment Analysis · Docket FS-2025-0001

FS-2025-0001-542231

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the agency's economic analysis relies on national averages rather than local impacts, fails to quantify the increased wildfire risk from new roads despite its own data showing higher ignition density near roads, and improperly excludes foreseeable plan amendments from the scope of the rulemaking while soliciting comment on them.

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

Environmental Protection Biodiversity
- “shelter black bear, hellbender, brook trout, Indiana bat, northern long-eared bat, and Virginia spiraea”
- “more tree species grow than in all of northern Europe”
- “we love being in nature and seeing the wildlife”
- “destroying nature for no reason”
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”
- “Opening roadless areas to new road construction would... move ignition rates sharply in the wrong direction”
- “minimize these forest fires”
Governance Policy Process
- “The agency cannot simultaneously declare plan amendments out of scope and ask the public to comment on them”
- “The Forest Service took more than 600 public meetings and 1.6 million comments to write the rule it now proposes to undo with none”
- “The agency must analyze the foreseeable plan-amendment scenario... rather than walling it off”
- “I ask that the agency withdraw the certification and assess the impact on the small entities”
Economic Impact Fiscal
- “books lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides and tour operators as affected”
- “The agency is already $6.9 billion behind on maintaining the roads it has”
- “being irresponsible with money that could go to a better cause”

What it names

National Forests: Cherokee National Forest

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 places that pull my family into the woods, Cherokee in NC among them, were built up slowly by forces that do not wait for agency rulemaking. Rescinding the 2001 Roadless Area Conservation Rule would put that inheritance at risk, and I oppose it. The Cherokee National Forest holds 18 inventoried roadless areas totaling 84,881 acres. Places like Citico Creek, Big Frog Mountain, and Bald River Gorge shelter black bear, hellbender, brook trout, Indiana bat, northern long-eared bat, and Virginia spiraea, among others, in a region where more tree species grow than in all of northern Europe. My family has gone to Cherokee and to parks far beyond it, from Yellowstone to Acadia, because we love being in nature and seeing the wildlife. What we photograph is just nature and all the diverse creatures and plants you see. These are not abstract values. They are the reason we go. The agency's economic analysis does not hold together. 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 was reached by averaging projected losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits near the affected roadless areas. The agency concedes some of those firms may lose those receipts entirely. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in or adjacent to the potentially affected roadless areas, not the national average firm. The reliance question is equally unresolved. 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 who have planned trips, outfitters who have built businesses, and communities whose economies depend on recreation in roadless country have organized around the rule's stability for over two decades. This comment is one such reliance interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. On fire, the agency's own data undercuts the proposal. 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. I have not been directly affected by wildfire, but it is sad to see and hear other people who are. We as a community should want to do whatever we can to minimize these forest fires. Opening roadless areas to new road construction would, by the agency's own numbers, move ignition rates sharply in the wrong direction. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it explicitly against any claimed reduction in wildfire hazard before this rule can be finalized. The process question matters just as much. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). The agency cannot simultaneously declare plan amendments out of scope and ask the public to comment on them. A logged stand grows back. A road does not. The Forest Service took more than 600 public meetings and 1.6 million comments to write the rule it now proposes to undo with none. That asymmetry alone is reason to pause. Beyond the process, no I do not think we should be building more things that cannot be properly maintained over time. You are destroying nature for no reason at that point and being irresponsible with money that could go to a better cause. The agency is already $6.9 billion behind on maintaining the roads it has, against a road budget of about $73 million a year. Adding new roads into country that currently has none compounds that deficit while permanently altering the landscape. The agency must analyze the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action rather than walling it off. Future generations should inherit at least what we have. I do not think we should do anything less than everything in our power to let them experience the beauty of nature without destroying it. The record does not support rescission. Sincerely, Danielle Palm Winston Salem, NC