Comment Analysis · Docket FS-2025-0001

FS-2025-0001-577672

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

In short: The comment documents that the agency's proposal to rescind the 2001 Roadless Area Conservation Rule fails to reconcile its own data on sedimentation, wildfire ignition rates, and economic costs with the rescission, and requests that the agency deny the rescission to maintain the 2001 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

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

Water Quality Quantity
- “7,000 municipal water intakes sit in watersheds fed by roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “Putting sediment into those watersheds makes water unsafe to drink and use”
- “increased sedimentation risk to drinking water supplies”
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 draft environmental impact statement”
- “far higher fire density on roaded land than inside the affected roadless areas”
Legal Regulatory Framework
- “The Tenth Circuit held... REVERSE the district court's order”
- “found the 2001 rule within the authority Congress granted under the Organic Act”
- “The Ninth Circuit examined the last attempt to replace the national rule with state petitions and found it deficient”
- “agency must address how this proposal avoids those same deficiencies”
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”
- “agency's road maintenance backlog already stands at $6.9 billion”
- “constitute sound management of public land”

What it names

National Forests: Uinta National Forest
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 The Uinta National Forest is not abstract wilderness to me. I have hiked and visited the lake there, and what I want for that land, and for public land generally, is simple: stop destroying our forests and harming the environment. We cannot keep doing it. That is the frame through which I read this proposal, and what I read concerns me. On water, the numbers the agency itself has compiled are striking. More than 7,000 municipal water intakes sit in watersheds fed by roadless areas, and roughly 24 million Americans drink water that begins there. Fewer than 12 percent of those watersheds have impaired streams today. The agency's own analysis shows that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I already know that a lot of people do not have reliable access to clean water. Putting sediment into those watersheds makes water unsafe to drink and use, and it costs a great deal of money to fix. What the agency has not explained is how rescinding the rule that protects the source watersheds is consistent with keeping that sediment load low. I ask that the agency address this directly, with specific reference to how the proposal accounts for increased sedimentation risk to drinking water supplies currently protected under the 2001 rule. On wildfire, the agency's 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 proposal justifies rescission in part on fuels and fire management grounds. That justification runs directly against the finding just quoted. I ask that the agency explain on the record why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it reconcile 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 record states: "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 projected timber revenue to the Forest Service of $5.2 to $11.4 million a year, the agency's own cost-benefit analysis projects recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency's road maintenance backlog already stands at $6.9 billion. How does expanding a road system carrying that backlog, for a commodity contribution the agency itself measures in fractions of a percent, constitute sound management of public land? On the legal record, the agency now argues that the 2001 rule exceeded its statutory authority. The courts that reviewed that question disagreed. The Tenth Circuit 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." That court found the 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not treat it as creating de facto wilderness. The agency has not explained what has changed in the governing law. I ask that it do so. Finally, on the state-by-state approach the proposal advances as an alternative, the agency's own record already contains this: "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 Ninth Circuit examined the last attempt to replace the national rule with state petitions and found it deficient. The agency must address how this proposal avoids those same deficiencies, and must acknowledge its own prior finding that incremental local decision-making erodes nationally significant roadless values over time. I am asking the agency to deny this rescission and to keep the 2001 Roadless Area Conservation Rule in place. Sincerely, Neil Raman Salt Lake City, UT