Comment Analysis · Docket FS-2025-0001

FS-2025-0001-587174

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's Cost Benefit Analysis and regulatory flexibility analysis fail to reconcile the marginal timber and oil/gas production gains against quantified recreation losses, small business impacts, unweighed reliance interests, and increased wildfire risks from road access in Florida'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

A2 moderate: Hard to dismiss — it shows cause and effect.

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.
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.

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.
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

Recreation Tourism Public Use
- “worth more to the people of this state for hunting, camping, and recreation”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “recreation losses the agency's own Cost Benefit Analysis books at a minimum of $6.1 million a year”
Water Quality Quantity
- “378 municipal water intakes sit in watersheds containing affected roadless areas”
- “communities whose water supply depends on keeping these watersheds intact”
- “reliance interests... including the interest of communities whose water supply depends on keeping these watersheds intact”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “timber revenue projected at only $5.2 to $11.4 million a year”
- “road maintenance backlog already standing at $6.9 billion”
- “agency cannot show a clear net benefit from this action using its own numbers”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The three National Forests within a day's drive of millions of Floridians are worth more to the people of this state for hunting, camping, and recreation than they could ever be worth for their timber. Florida holds 9 inventoried roadless areas totaling 50,482 acres. Those acres are among the few natural forests remaining in Florida, and the case for opening them to roads and extraction has not been made. The agency's own numbers undercut the economic rationale for this rescission. The record states 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." Those figures describe a marginal contribution to national supply set against recreation losses the agency's own Cost Benefit Analysis books at a minimum of $6.1 million a year, timber revenue projected at only $5.2 to $11.4 million a year to the Forest Service, a net present value spanning from negative $92 million to positive $199 million, and a road maintenance backlog already standing at $6.9 billion. The agency cannot show a clear net benefit from this action using its own numbers. I ask that it reconcile the proposal with that analysis and explain how it justifies expanding a road system already carrying that backlog when the Cost Benefit Analysis cannot establish the action pays. The regulatory flexibility analysis reaches a no-significant-impact conclusion by spreading economic losses across every small firm in the sector nationally, rather than examining the outfitters, guides, and tour operators who actually hold permits in the affected areas and whom the DEIS names as affected parties. The DEIS itself books lost recreation benefit at a minimum of $6.1 million a year and concedes some firms may lose those receipts. "The proposed rule certifies no significant impact on small entities while the 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 contradiction is not resolved by averaging harm away across firms that will never feel it. The agency should withdraw the certification and assess the impact on the small businesses actually operating in or adjacent to the affected roadless areas. In the Southern region, which includes Florida, 378 municipal water intakes sit in watersheds containing affected roadless areas. The people served by those intakes have organized their expectations around the protections the 2001 rule provides. Yet the agency's invitation for comment makes plain that reliance interests have not been weighed. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." This comment is one such interest. When an agency changes course it is required to account for the reliance its prior policy created, and the Cost Benefit Analysis beside this proposal contains no such accounting. The agency must identify and weigh the reliance interests described in the comments it receives, including the interest of communities whose water supply depends on keeping these watersheds intact. The agency's fire data also cuts against rescission rather than for it. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis concedes that road access could increase the number and frequency of wildfires. Florida's forests are not abstractions; they are places people use, and a fire regime made worse by new road access imposes costs on recreation and on communities that the proposal does not quantify. The agency must calculate the expected increase in human-caused ignitions from new road access and place that figure in direct comparison with whatever wildfire hazard reduction it claims the rescission would achieve. Sincerely, Susan Carr 1546 SW 35th Place Gainesville, FL 32608