Comment Analysis · Docket FS-2025-0001

FS-2025-0001-543281

Opposes rescissionA1 strongSubstance 13/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the agency's draft EIS and cost-benefit analysis contain internal contradictions regarding wildfire ignition risks and net economic benefits, and cites a Tenth Circuit ruling affirming the 2001 Roadless Rule's statutory authority, thereby placing on the record specific deficiencies in the agency's justification for 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

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

Environmental Protection Biodiversity
- “endangered red-cockaded woodpeckers and the protected pygmy rattlesnakes”
- “endemic carnivorous plants found nowhere else in the world”
- “how important biodiversity is”
- “wildlife persists”
Recreation Tourism Public Use
- “I hike and camp there with my dog because it keeps us both healthy”
- “go specifically where cars cannot reach”
- “hold still in a quiet place and let animals act naturally”
- “recreation losses of at least $6.1 million a year”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “ignition risk the agency's own findings document”
- “far higher fire density on roaded land than inside the affected roadless areas”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “timber revenue to the Forest Service of between $5.2 and $11.4 million a year”
- “net present value that spans from -$92 million to +$199 million”
- “agency is already $6.9 billion behind on maintaining the roads it has”

What it names

National Forests: Croatan National Forest
Law cited: 28 U.S.C. Section 1291

The comment

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

The Croatan National Forest is one of the last wild stretches of land on the North Carolina coast, and it belongs to the public. I hike and camp there with my dog because it keeps us both healthy, physically and mentally. It is how we escape the world for a bit, together. I go specifically where cars cannot reach, because that is how wildlife persists. That is where I watch the endangered red-cockaded woodpeckers and the protected pygmy rattlesnakes, where I find the slowly reproducing turtles, where I see endemic carnivorous plants found nowhere else in the world, where I can hold still in a quiet place and let animals act naturally without humans and cars interfering. I am a naturalist, and I recognize how important biodiversity is, and how lucky we are to have such amazing wildlife in this country. The Croatan is imperative for future North Carolinians so they can enjoy these lands too. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The agency's own record destroys its own justification for using wildfire as a reason to open roadless areas. The record 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." North Carolina holds 172,416 acres across 38 inventoried roadless areas. Every acre of that land that gains a road gains exactly the ignition risk the agency's own findings document. I ask that the agency explain, in this proceeding, why the proposal departs from these prior findings and how it reconciles the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is just as hollow. The agency's own record acknowledges 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." Against that marginal gain, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of between $5.2 and $11.4 million a year, set against recreation losses of at least $6.1 million a year, and a net present value that spans from -$92 million to +$199 million. My money should be spent maintaining what we already have and preserving it, not ruining our lands for someone else's profit. The agency is already $6.9 billion behind on maintaining the roads it has, running on a road budget of roughly $73 million a year. The agency must reconcile the proposal with that cost-benefit range and explain how any action whose own analysis cannot establish a net benefit justifies adding more road infrastructure to a system already failing under the weight of deferred maintenance. The agency argues that state-by-state approaches can substitute for a single national rule, but the record shows the agency's "dissatisfaction with the Roadless Rule" and its rejection of the Roadless Rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. The agency has already attempted to substitute local decision-making for national protection and has already been found wanting for it. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time the agency replaced the national rule with a state-by-state approach. Finally, the proposal argues the 2001 rule exceeded statutory authority, but a federal appellate court has already answered that question. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule within the authority Congress granted under the Organic Act and MUSYA and ruled it did not create de facto wilderness. The agency should explain, with specificity, the legal basis for any position contrary to that holding. Across the Southern region alone, 378 municipal water intakes sit in watersheds containing affected roadless areas. The Croatan is not an abstraction. The wildlife I watch there, the quiet I go there for, the land that future North Carolinians deserve to inherit: none of it survives a road network built for timber revenues that the agency's own numbers cannot justify. Sincerely, Lauren Wilson North Carolina