Comment Analysis · Docket FS-2025-0001

FS-2025-0001-571778

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's justification for rescinding the Roadless Rule is contradicted by its own data on wildfire ignition risks (DEIS Table 21), its cost-benefit analysis showing a wide net present value range and high maintenance backlogs, and its regulatory flexibility analysis which fails to assess specific impacts on local small businesses in named roadless areas.

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

Recreation Tourism Public Use
- “Quiet, peace, nature, and water: those are the things I go to the woods and lakes for”
- “They are for the public to enjoy, not for logging or mining”
- “recreation losses of at least $6.1 million a year”
- “outfitters, guides, and tour operators as affected”
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”
- “Opening those landscapes to road construction would increase ignition risk”
- “reconcile the rescission with the ignition data in DEIS Table 21”
Water Quality Quantity
- “watersheds holding 286 municipal water intakes inside the affected areas”
- “water: those are the things I go to the woods and lakes for”
- “paddle Lake Michigan and Lake Superior”
- “hike and camp near lakes in Northern Wisconsin”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value ranging from -$92 million to +$199 million”
- “Forest Service already carries a $6.9 billion road maintenance backlog”
- “recreation losses of at least $6.1 million a year”

What it names

National Forests: Chequamegon-Nicolet National Forest Huron-Manistee National Forest Shawnee National Forest
Roadless areas: Bay CreekBear SwampBurden FallsBurke BranchClear SpringsEagle CreekRipple Hollow
Law cited: 36 C.F.R. Section 294.12

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Quiet, peace, nature, and water: those are the things I go to the woods and lakes for, and the 2001 Roadless Area Conservation Rule has protected the places where I find them. I oppose its rescission. I paddle Lake Michigan and Lake Superior. I hike and camp near lakes in Northern Wisconsin and have traveled to Shawnee National Forest in Illinois. The roadless areas I care about most directly, including Bear Swamp in the Huron-Manistee National Forest in Michigan, the island and lake units of the Chequamegon-Nicolet National Forest in Wisconsin, and the Burke Branch, Ripple Hollow, Burden Falls, Bay Creek, Eagle Creek, and Clear Springs areas in the Shawnee, are public land. They are for the public to enjoy, not for logging or mining. That is not a slogan; it is the conclusion I have reached after traveling to these places repeatedly over the years. The agency justifies rescission in part on wildfire and fuels management grounds, but its own record directly contradicts that argument. The agency's prior findings state: "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." That sentence does not describe a fringe position; it is the agency's own language, drawn from its own environmental review. Bear Swamp sits within Michigan's 16,124 acres of inventoried roadless land, and the Eastern region, which includes Michigan, contains watersheds holding 286 municipal water intakes inside the affected areas. Opening those landscapes to road construction would increase ignition risk precisely where the agency's own data says roaded land burns harder. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is no stronger. The agency's own record concedes 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 of $5.2 to $11.4 million a year to the Forest Service, set against recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, a span so wide it cannot establish a benefit. The Forest Service already carries a $6.9 billion road maintenance backlog. I ask that the agency reconcile the proposal with those numbers and explain how it justifies expanding a road system that the agency cannot currently maintain, when its own analysis cannot confirm a net gain. The permitting burden rationale fares no better under scrutiny. The rule as written already provided that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The exceptions for public health, safety, existing mineral leases, and community wildfire protection are already in the rule. The agency has not identified, with specificity, which burdens those provisions fail to address. I ask that the agency name the particular burdens the existing exceptions do not resolve, and quantify them on the record. Finally, the regulatory flexibility analysis certifies no significant impact on small entities, but the record itself names outfitters, guides, and tour operators as affected, and books a minimum recreation benefit loss of $6.1 million a year. The certification is reached by spreading expenditure losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in these specific roadless areas. The Thornapple and Le Roy Creek areas in the Chequamegon-Nicolet, along with the Shawnee units I named above, all support recreational use that feeds exactly those small businesses. A certification built on a national average rather than on the affected permit holders is not an analysis; it is an assumption. The agency must withdraw that certification and assess the impact on the businesses actually operating in these areas. These places belong to the public. Rescission serves none of the purposes the agency claims for it, and the agency's own record says so. I urge that the 2001 Roadless Area Conservation Rule be retained without modification. Sincerely, Katrina Burmeister Sleepy Hollow IL