Comment Analysis · Docket FS-2025-0001

FS-2025-0001-559584

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment establishes that the DEIS inadequately analyzes the economic and environmental impacts of rescinding the Roadless Rule, specifically regarding recreation losses, wildfire ignition risks, and ecosystem fragmentation, while documenting the commenter's personal use of specific protected areas and requesting a thorough FEIS analysis of these impacts and alternative management strategies.

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

Recreation Tourism Public Use
- “I hike, bike, go birding, do photography in Southern Massanutten dozens of times a year”
- “I ask that the FEIS provide a thorough analysis of lost visitor spending and local economic multipliers”
- “It provides access to people who love to hike, camp, and fish”
Environmental Protection Biodiversity
- “building new roads will fragment ecosystems, which are already fragile”
- “Fragmentation by roads has been found to reduce biodiversity by 13-75%”
- “The Roadless rule preserves ecosystems – lands, rivers, flora, and fauna”
Forest Management Wildfire
- “The USDA's argument that rescinding the Roadless rule will prevent large wildfires is not credible”
- “78% of human-caused wildfires on National Forest start within ½ a mile of a road”
- “The Roadless rule does not preclude forest management activities that help reduce the risk of wildfire”
Water Quality Quantity
- “squandered it – our fresh water, our clean air”
- “healthy ecosystems gives us clean air, clean water to drink”
- “drink clean water, and eat healthy food”

What it names

Roadless areas: Gum RunLittle RiverMt. ZionOak KnobSan DimasSeneca CreekSouthern Massanutten
Works cited: Haddad et al. 2015

The comment

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

It was only 500 years ago when the United States had no roads at all. I ask you to reflect on what the forests, the streams, and lands must have looked like then. Imagine cresting a hill to see nothing but wild lands until the far ocean. Imagine watching buffalo and salmon migrating by the millions. Today in 2026, we cannot fathom what the lands and streams once looked like, just like future generations will be shocked that we had the chance to protect what we have and squandered it – our fresh water, our clean air, our game and fishing populations, our recreation spaces, our wild places. To date, we have only managed to protect a fraction of our lands (for example, the Roadless rule protects fewer than 60 million of the nearly 2 billion acres in the US). I am writing in strong support of maintaining the protections of the 2001 Roadless Area Conservation Rule. This is deeply personal. Many of the regions protected by the Roadless rule are areas that I frequent. I hike, bike, go birding, do photography in Southern Massanutten dozens of times a year. I have also hiked, camped, birded, and explored other Virginia/West Virginia regions including: Dry River, Skidmore, Oak Knob, Gum Run, Little River, Seneca Creek, and Dolly Sods. On the West Coast, I have hiked, camped, birded, and explored Quilcene, Mt. Zion, Alpine Lakes Adj, Thorp Mtn, Teanaway, Eagle, Larch, and San Dimas regions – among many others. As an outdoors enthusiast, I believe the DEIS inadequately addresses the recreation losses from road construction and downstream activities, and I ask that the FEIS provide a thorough analysis of lost visitor spending and local economic multipliers in all impacted regions and specifically the regions named above. Without such analysis, the agency misrepresents the economic impact of rescinding this rule. The USDA’s argument that rescinding the Roadless rule will prevent large wildfires is not credible. 78% of human-caused wildfires on National Forest start within ½ a mile of a road (based on USDA data). The Roadless rule does not preclude forest management activities that help reduce the risk of wildfire. I ask the agency to quantify the expected increase in human-caused ignitions resulting from new road access and to quantify it against claimed reductions in wildfire hazard. I am specifically interested to see this analysis in the regions mentioned above and also in all impacted regions. Furthermore, building new roads will fragment ecosystems, which are already fragile as humans continue to develop and build. Fragmentation by roads has been found to reduce biodiversity by 13-75% (Haddad et al. 2015). Once again, healthy ecosystems gives us clean air, clean water to drink, pollinators to keep our crops productive, healthy soils to grow healthy food for healthy children, beautiful lands that people travel from around the world to see, etc. I ask that the agency provide an economic and environmental analysis of the negative impact of ecosystem fragmentation from new roads on these critical environmental benefits and ecosystem services. Finally, if the agency is looking to create more rural jobs, which I wholeheartedly support, I suggest creating jobs that help preserve these precious ecosystems - it would be a win-win for everyone. Given the agency’s goal of wildfire management and rural job creation, I ask that the FEIS include an analysis of alternative methods to accomplish their goal. I believe that it would be insufficient to consider rescinding the Roadless Rule without a careful economic and environmental analysis of alternative options, including greater funding for job creation around fire fighting, invasive species management, existing road repair, and forest management. I am writing this as an outdoor enthusiast, an angler, a birder and wildlife lover, an artist whose work is inspired by the natural places that I explore, and a passionate environmentalist. The Roadless rule preserves ecosystems – lands, rivers, flora, and fauna. It provides access to people who love to hike, camp, and fish (like me), and who simply want to breathe clean air, drink clean water, and eat healthy food (also like me). Let us keep our lands as wild and healthy as possible – for the land, for ourselves, and for our children. Thank you.