Comment Analysis · Docket FS-2025-0001

FS-2025-0001-575731

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents the commenter's personal connection to specific national forests in Georgia and Utah, cites the agency's own 'Summary of Potential Impacts' to argue that timber benefits are negligible compared to the Forest Service's repair backlog, and requests the withdrawal of the proposed rescission of the 2001 Roadless Area Conservation Rule.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Analytical gap.

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.
  • 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.
  • 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.
  • 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

  • Water Quality Quantity
    • “help supply drinking water for millions of Georgians”
    • “protect the water we drink”
    • “Georgia has about 63,000 roadless acres... protect parts of the Appalachian and Benton MacKaye trails”
  • Forest Management Wildfire
    • “The 2001 rule includes exceptions for cutting small trees to lower wildfire risk”
    • “more public access can increase human-caused fires”
    • “planned, controlled burns are an important tool for keeping forests healthy”
  • Recreation Tourism Public Use
    • “grew up hiking and camping in Utah's national forests”
    • “hiking, camping, and having cookouts in the Uinta-Wasatch-Cache National Forest”
    • “These lands belong to all Americans”
  • Economic Impact Fiscal
    • “highest timber revenue estimate is $11.4 million per year”
    • “Forest Service already has a $6.9 billion backlog of road and bridge repairs”
    • “New roads would add to a bill the agency cannot pay now”

What it names

National Forests
Chattahoochee National ForestTongass National ForestWasatch-Cache National Forest

The comment

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

RE: RIN 0596-AD66, Docket FS-2025-0001 I live in Pooler, Georgia, and I grew up hiking and camping in Utah's national forests. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Please keep it in place nationwide, including in the Tongass National Forest. 1. USDA's own numbers show little benefit. The "Summary of Potential Impacts" section says new management chances would be "modest and localized." The highest timber revenue estimate is $11.4 million per year. The Forest Service already has a $6.9 billion backlog of road and bridge repairs. Even that highest estimate equals less than 0.2% of the backlog each year. New roads would add to a bill the agency cannot pay now. 2. Wildfire work is already allowed. The 2001 rule includes exceptions for cutting small trees to lower wildfire risk. The proposed rule also admits that more public access can increase human-caused fires (Summary of Potential Impacts, "Wildfire risk"). If the exceptions are too slow to use, USDA should speed up that review process. It should not remove the whole rule. 3. Georgia's roadless areas matter. Georgia has about 63,000 roadless acres in the Chattahoochee National Forest. These lands protect parts of the Appalachian and Benton MacKaye trails and help supply drinking water for millions of Georgians. Forest plans can be changed much more easily than a national rule. Protection for these places should not depend on each plan revision. 4. National forests belong to everyone. These lands belong to all Americans, not just the people near them. A national rule is the right tool for national lands. I grew up in Utah. I spent many weekends and summer days hiking, camping, and having cookouts in the Uinta-Wasatch-Cache National Forest. I thought easy access to national forests was normal in every state. Now that I live in Georgia, I know how rare these lands are. They matter for their beauty, and they also protect the water we drink, the air we breathe, and the plants and animals that live there. These benefits are hard to put a dollar value on, but USDA should still weigh them against the small timber gains. I also understand wildfire. This year, both Utah and Georgia saw dangerous fires. I know that fire is a natural part of a forest's life cycle, and that planned, controlled burns are an important tool for keeping forests healthy. Wildfires that people start by accident are different. Visitors often underestimate how fast a campfire or a tossed cigarette can get out of control. Roads bring more people into wild areas, and more people mean more human-caused fires. That is a risk USDA's own proposal admits. Please withdraw the proposed rule and keep the 2001 Roadless Rule.

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