Comment Analysis · Docket FS-2025-0001

FS-2025-0001-575421

Opposes rescissionA1 strongSubstance 12/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding sediment impacts on trout, wildfire ignition risks on roaded lands, and the lack of net economic benefit, while citing specific locations in Wisconsin and Michigan and the Tenth Circuit's legal validation of the 2001 Roadless Rule to support a request to withdraw the rescission proposal.

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 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
- “Every species benefits from large areas of untrammeled land”
- “The quiet is gone, the patterns shift, and the habitat those animals depend on starts to fray at the edges”
- “More disturbance is not good for habitat”
Water Quality Quantity
- “fish depend on clean, well-oxygenated water”
- “sediment wash off a road during a rainstorm and turn the water turbid”
- “286 municipal water intakes sit in watersheds containing affected roadless areas”
Forest Management Wildfire
- “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”
- “far higher fire density on roaded land than inside the affected roadless areas”
Legal Regulatory Framework
- “A federal appellate court already answered that question, reversing a district court injunction and ruling that the rule was valid”
- “The agency must address the Tenth Circuit's holding that the 2001 rule fell within authority Congress granted”
- “it must state clearly the legal basis for any position to the contrary”

What it names

Roadless areas: Bear Swamp
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 knowledgeAnalytical gapEvidenceRequestAlternativeLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting since I was 12, now 54 years in, I have watched what happens to country when roads find it. That experience shapes every word below, and it is why I oppose the rescission of the 2001 Roadless Area Conservation Rule as proposed under Docket FS-2025-0001. The inventoried roadless areas in Wisconsin and Michigan that I care about, including Round Lake Study Area, Shelp Lake, Chase Creek, Bear Swamp, Wheeler Lake Islands, and Shoe Lake Islands, hold values that roads and the disturbance that follows them do not restore. Every species benefits from large areas of untrammeled land. That is not sentiment; it is what 54 years of hunting teaches you. The moment a road enters a landscape, something changes about how animals use it. The quiet is gone, the patterns shift, and the habitat those animals depend on starts to fray at the edges. More disturbance is not good for habitat, and that is reason enough to keep the protection in place. I have been fishing for many species for 58 years, and fish depend on clean, well-oxygenated water. Many species depend on cold water. Trout in particular are sensitive to what happens to a stream when a road sits nearby. I have seen sediment wash off a road during a rainstorm and turn the water turbid, and I know what that does to a trout stream. The agency's own record confirms the mechanism: roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale, and sedimentation from harvest can promote excessive substrate movement and cause egg and juvenile mortality and reduced suitable habitat for fish such as bull trout. Wisconsin alone holds 16 inventoried roadless areas totaling 68,987 acres, and across the Eastern region 286 municipal water intakes sit in watersheds containing affected roadless areas. I would hope that clean water is everyone's concern. Keeping our wilderness watersheds in good condition benefits us all, and more roads do not help. I ask that the agency explain specifically how it expects to protect trout and the cold, clear streams they require if the sediment controls that come with roadless status are removed. The opportunity to hike into remote areas is one of the greatest gifts we have in this country, and I camp all over it. I am always in search of species I have not observed previously, and that search depends on places that remain intact. These are not abstract amenities. They are what these areas actually provide, and the proposal does not account for what is lost when they are gone. On wildfire, the agency argues that rescission serves fuels management, yet its own 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." The agency must explain why this proposal departs from that finding 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. On economics, the agency's own analysis 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." The agency's cost-benefit analysis 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 the Forest Service already carries a $6.9 billion road maintenance backlog. The agency cannot establish a net benefit from this action and must reconcile that with the proposal on the record. On prior legal authority, the agency now questions whether the 2001 rule was within its statutory power. A federal appellate court already answered that question, reversing a district court injunction and ruling that the rule was valid. The court 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." The agency must address the Tenth Circuit's holding that the 2001 rule fell within authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and it must state clearly the legal basis for any position to the contrary. The record does not support this rescission. I urge the agency to withdraw the proposal. Sincerely, Charles Johnson Verona, Wi