Comment Analysis · Docket FS-2025-0001

FS-2025-0001-542903

Opposes rescissionA2 moderateSubstance 7/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS contains internal contradictions regarding wildfire ignition risks, economic net benefits, and biological integrity, and documents specific data points (road maintenance backlog, sediment production, bird abundance decline) that the commenter argues demonstrate the proposal's failure to reconcile its own findings with the proposed rescission.

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.

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

Forest Management Wildfire
- “The wildfire argument the agency uses to justify rescission collapses against the agency's own words”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “why is new road construction being offered as a fire solution”
Wildlife Habitat
- “bird richness declines with road presence in forested habitat”
- “road-noise experiments in a roadless area cut bird abundance by over a quarter”
- “protect the many species dependent on these lands and trees”
Water Quality Quantity
- “More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “degrading the source watersheds that supply drinking water to some 24 million Americans”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total U.S. production”
- “agency already carries a $6.9 billion road maintenance backlog”
- “recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million”

What it names

Works cited: Kroeger et al. 2022

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequestAlternativeLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The world God made is full of life and chaos, and every time I hike or camp I am trying to reach it, if only for a moment. The more we impose ourselves on those untouched spaces, the more we strip the world of God. Please, in this nation under God, do not destroy His work. Rescinding the 2001 Roadless Area Conservation Rule would do exactly that, and I oppose it completely. The wildfire argument the agency uses to justify rescission collapses against the agency's own words. The DEIS 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." Forest fires already infect the air breathed across the entire country. If the agency's own record shows that roads increase ignition risk at nearly that ratio, why is new road construction being offered as a fire solution? I ask that the agency explain why this proposal departs from its own prior findings and data. On economics, the agency should be honest about what its own numbers say. The record before the agency states: "the total timber volume affected by this rule is less than 0.5 percent of total U.S. production, and the total oil and gas production from all NFS lands is currently about 0.4 percent of the current national production." We don't have enough land to consume in the way we go through smart phones. The classic consumerist mindset of wanting new instead of maintaining and fixing the used and worn is not a sound basis for federal policy. The agency already carries a $6.9 billion road maintenance backlog on a budget of about $73 million a year. The agency should reconcile this proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already that deep in arrears. The birds are the music we are meant to hear, and the volume is turned down every tree that is cut down. That is not sentiment alone. The agency's own DEIS, citing Kroeger et al. 2022, McClure et al. 2013, and Ware et al., documents that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Roads silence the landscape. The agency must address what this body of evidence, cited in its own DEIS, means for the biological integrity of the areas it proposes to open, and must explain why that finding does not weigh decisively against rescission. I became deeply sad when I realized that some global ancient areas I had visited were shutting down or limiting access because of deterioration under tourist foot traffic. And here we are, potentially choosing to tear down the American version of historic ancient grounds, places our descendants could never see or experience, for profit that historical precedent suggests is highly unlikely to materialize. The agency also needs to reckon with water. More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas, and the agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The administration has already moved to treat clean drinkable water as something less than a human right. The agency should not let that become the norm by degrading the source watersheds that supply drinking water to some 24 million Americans, and it must state on the record what alternative protection it is offering those communities. Finally, the agency tried replacing this national rule with a state-by-state approach once before. The record reflects that the USDA "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit rejected that substitution. The agency must address how this proposal avoids repeating the same legal deficiencies and must explain why local decision-making, which the agency's own prior findings said could incrementally erode nationally significant roadless values, is now adequate. Raw and roadless and real. That is what public land should be. With guidance from the native tribes that managed these lands for centuries before our ancestors arrived, we could preserve water supplies, protect the many species dependent on these lands and trees, and reduce the fire risk the agency claims to be addressing. Rescission does the opposite. I urge the agency to withdraw this proposal. Sincerely, Susi Overland Park, Kansas