Comment Analysis · Docket FS-2025-0001

FS-2025-0001-579821

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Area Conservation Rule is internally inconsistent with its own DEIS and Cost Benefit Analysis regarding wildfire ignition risks, economic net benefits, and small business impacts, specifically within the Hiawatha National Forest's 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, 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

Environmental Protection Biodiversity
- “complex, interdependent wilderness habitat”
- “survival of God's creatures”
- “beauty of the wild places”
- “legacy at risk”
Forest Management Wildfire
- “wildfire rationale offered for rescission collapses”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “ignition data in its own draft environmental impact statement”
- “far higher fire density on roaded land”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent”
- “recreation losses of at least $6.1 million a year”
- “net present value ranging from -$92 million to +$199 million”
- “road system already carrying a $6.9 billion maintenance backlog”
Legal Regulatory Framework
- “agency's own record does not support the action”
- “rule as written already states that it 'generally banned road building subject to limited exceptions'”
- “small-business certification accompanying this proposal cannot survive scrutiny”
- “agency should withdraw the certification”

What it names

National Forests: Hiawatha National Forest
Roadless areas: FibreGovernment IslandRound Island
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 gapEvidenceRequestLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Hiawatha National Forest, where I hike, camp, canoe, photograph, sketch, and paint, holds some of what remains of God's creation in Michigan. Human beings cannot create complex, interdependent wilderness habitat. We are part of that creation. We need it intact for our very survival and the survival of God's creatures. The beauty of the wild places, including Round Island, Government Island, and the Fibre roadless area, is our legacy. The rescission of the 2001 Roadless Area Conservation Rule would put that legacy at risk, and the agency's own record does not support the action it proposes. The wildfire rationale offered for rescission collapses under the weight of the agency's own prior findings. The 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 Hiawatha's inventoried roadless areas, including the 7,432-acre Fibre unit, carry precisely the kind of habitat that this finding was meant to protect from ignition by access. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and 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. 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 minimal extractive contribution, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, 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 spread so wide it establishes nothing. Michigan alone holds 6 inventoried roadless areas totaling 16,124 acres, and 286 municipal water intakes across the Eastern region sit in watersheds containing affected roadless areas. The agency cannot show a net benefit, yet it proposes to expand a road system already carrying a $6.9 billion maintenance backlog. I ask the agency to reconcile that arithmetic, on the record, before proceeding. The agency also misrepresents the rule as a blunt prohibition when it is nothing of the kind. The rule as written already states 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)." Emergency access, community wildfire protection, and existing mineral leases are not blocked by the rule. The agency has not identified which specific burdens remain unaddressed by those exceptions, and it has not quantified them. I ask the agency to do so before it treats administrative convenience as sufficient grounds to abandon protections covering places like Government Island and Round Island. Finally, the small-business certification accompanying this proposal cannot survive scrutiny. The agency certifies no significant impact on small entities while its own DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification was reached by spreading the estimated loss across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas, and the analysis itself concedes that some of those firms may lose these receipts entirely. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm.