Comment Analysis · Docket FS-2025-0001

FS-2025-0001-556781

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the Roadless Rule is contradicted by its own DEIS data regarding wildfire ignition rates on roaded lands, wildlife survival dependencies on unroaded areas, and economic cost-benefit analyses showing no net benefit, specifically within the six inventoried roadless areas of the Chattahoochee National Forest.

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 rose during a road closure”
- “roads built for extraction may have altered mule deer migration routes”
- “open roads increase contact, conflict, habituation, food reward, and ultimately mortality”
- “Building new roads into Helton Creek, Lance Creek, or any of the other areas I named would directly degrade that habitat”
Water Quality Quantity
- “378 municipal water intakes sit in watersheds containing affected roadless areas”
- “water that can still be filtered”
- “Without enough trees to clean the air... or water that can still be filtered, none of the rest of it matters”
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”
- “reconcile the rescission with the ignition data in its own DEIS Table 21”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”

What it names

National Forests: Chattahoochee National Forest
Roadless areas: Boggs CreekCedar MountainHelton CreekLance CreekMiller CreekSmoky MountainsTurner Creek
Law cited: 28 U.S.C. Section 1291

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific place

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The fresh air my daughter breathes when we walk the creeks in the Great Smoky Mountains is the reason I am writing. I hike and camp there to walk in the water, fill my lungs, and raise her to love the same things I love. When I look for elk, bears, deer, turkeys, squirrels, owls, and other wildlife, I am not doing something recreational in any trivial sense. I am participating in something that has to exist for us to survive. That is not sentiment. It is a practical statement about air, water, and food, and I will explain exactly what I mean. Six inventoried roadless areas in the Chattahoochee National Forest in Georgia are directly at stake in this proceeding: Helton Creek, 2,348 acres; Cedar Mountain, 1,083 acres; Turner Creek, 1,495 acres; Boggs Creek, 2,073 acres; Miller Creek, 701 acres; and Lance Creek, 9,025 acres. Georgia holds 23 inventoried roadless areas totaling 63,351 acres. Across the Southern region, which includes Georgia, 378 municipal water intakes sit in watersheds containing a!ected roadless areas. These are not abstractions. Without enough trees to clean the air, enough bees to pollinate and grow our vegetables, or water that can still be filtered, none of the rest of it matters. Not 100 years from now, but five years from now, 1 year from now. That urgency is why I oppose the rescission of the 2001 Roadless Area Conservation Rule. The agency justifies this proposal in part on wildfire management. Its own record contradicts that justification directly. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire e!ects 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." I ask that the agency explain why this proposal departs from that finding, and that it reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the a!ected roadless areas. The elk and deer I look for depend directly on the absence of roads. The agency's own record found that elk survival rates rose during a road closure and fell again when the gates were https://morethanjustparks.com/roadless-rule/?fbclid=PAdGRl3pXTT2wvNnb1iHAV0578f_ aem _ELXhYb8LjYub78doL6QXOA 10/5/26, 7:27 AM Page 1 of 3 removed. For deer, the DEIS cites research finding that roads built for extraction may have altered mule deer migration routes and increased their movement speed, disrupting the unroaded security these animals require. Bears are no di!erent: the DEIS quotes the federal grizzly recovery plan warning that open roads increase contact, conflict, habituation, food reward, and ultimately mortality. The black bear ranges through the Chattahoochee, at the southern end of the Appalachian chain where some of the wildest land in the southeastern United States still holds. Building new roads into Helton Creek, Lance Creek, or any of the other areas I named would directly degrade that habitat. We have enough roads. Wildlife needs land that is wild. The agency must explain how expanding the road network into these areas is consistent with the population data in its own environmental record. The economics do not support this either. The agency's own record states: "the total timber volume a!ected 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." The agency must reconcile the proposal with its own cost- benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service 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 carrying a $6.9 billion maintenance backlog. The state-by-state approach this proposal o!ers in place of a national rule is not new. The agency's own record reflects its prior position: "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 agency tried that path before and the Ninth Circuit found it wanting. The agency must address how this proposal avoids those same deficiencies, and must respond to its own prior finding that local decision-making can incrementally erode nationally significant roadless values. Finally, on the question of statutory authority, the Tenth Circuit already answered it: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plainti!s declaratory relief and issuing a permanent injunction, and REMAND the