Comment Analysis · Docket FS-2025-0001

FS-2025-0001-580092

Opposes rescissionA3 weakSubstance 12/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's draft EIS regarding wildfire risk and timber economics, cites industry data to refute the production argument, and requests the retention of the 2001 Roadless Rule based on the commenter's personal use of specific roadless areas in North Carolina, South Carolina, and Colorado.

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, Evidence.

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

Forest Management Wildfire
- “wildfire rationale does not hold up”
- “repealing the rule would deliver little or no wildfire risk reduction”
- “Building more roads would likely increase, not decrease, fire starts”
Water Quality Quantity
- “safeguards drinking water for roughly 25 million Americans”
- “across 82,000 miles of streams”
Wildlife Habitat
- “fragment wildlife habitat”
- “loss of protections for nearly 45 million acres”
Recreation Tourism Public Use
- “world-class backcountry recreation”
- “these places are irreplaceable”
- “Once roads and logging enter them, their character is gone forever”

What it names

Roadless areas: Craggy MountainSouth Mills RiverWilson Creek

The comment

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

Dear Secretary Rollins and the U.S. Forest Service, I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge you to retain the rule in its entirety. The wildfire rationale does not hold up • The Forest Service’s own draft environmental impact statement found that repealing the rule would deliver little or no wildfire risk reduction while increasing federal road maintenance costs. • Ninety-five percent of wildfires are started by people, and nearly two-thirds of those ignite along roadsides. Building more roads would likely increase, not decrease, fire starts. • The analysis projects only a 5–10% increase in timber harvest—adding roughly $5–11 million a year to a $288 billion industry—a trivial gain against the loss of protections for nearly 45 million acres. The timber production argument is contradicted by current industry conditions • U.S. sawmill capacity has dropped 6% in a single year, production has fallen for two straight quarters, and the mill workforce is at its lowest level since 2010. • Thirty-five hardwood sawmills closed in 2025 alone, and the industry has lost around 40,000 jobs since 2022. • In South Carolina, Canfor closed its Darlington sawmill in June 2025, and Interfor recently curtailed production at its Summerville plant, laying off about 90 workers. • The problem is demand, not supply. Weak housing construction and collapsing pulpwood markets mean there are no buyers for additional timber. Opening more forest to harvest does not create markets that do not exist. The rule protects critical resources and has broad public support • It safeguards drinking water for roughly 25 million Americans across 82,000 miles of streams. • Removing the national baseline would fragment wildlife habitat and shift decisions to local plans without guaranteed public involvement or environmental review at that scale. • The rule has survived 25 years of litigation. In the 2025 notice-of-intent period, more than 600,000 comments were submitted, over 99% opposing repeal. I have a deep personal connection to these landscapes. I have spent time in the roadless areas of the Pisgah and Nantahala National Forests in North Carolina (including Big Ivy, South Mills River, Craggy Mountain, and Wilson Creek) and in the Francis Marion and Sumter National Forests in South Carolina (including the Andrew Pickens district). I have also spent time in the Pike-San Isabel National Forest near Buena Vista, Colorado, where the Collegiate Peaks, Mount Massive, and Mount Elbert roadless areas provide world-class backcountry recreation. While Colorado’s lands remain protected under the state’s own 2012 roadless rule, the principle matters everywhere: these places are irreplaceable. Once roads and logging enter them, their character is gone forever. I respectfully request that the Forest Service select the alternative that retains the Roadless Rule as is. Sincerely, Matt Lugar