Comment Analysis · Docket FS-2025-0001

FS-2025-0001-587877

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's analysis fails to quantify the specific increase in human-caused wildfires resulting from road access, relies on national averages rather than local data for small entity impacts, and ignores stated reliance interests, thereby supporting the retention 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

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

Environmental Protection Biodiversity
- “black bears still roam and brook trout hold in the coldest headwater streams”
- “salamander species found nowhere else on Earth”
- “Verified species across these landscapes include hellbender, cerulean warbler, the northern long-eared bat”
- “protecting the last wild headwaters of rivers”
Recreation Tourism Public Use
- “Hiking nearly 900 miles of the Appalachian Trail”
- “protect the experience of encountering them without the intrusion of motorized traffic”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “direct, concrete reliance on the character that rule has maintained”
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”
- “claim a net wildfire benefit while declining to quantify the expected increase”
Legal Regulatory Framework
- “does not satisfy what the Regulatory Flexibility Act requires”
- “agency changing course is obligated to identify and assess the reliance interests”
- “specific analytical failures the agency has not resolved”
- “withdraw the certification and assess the impact on the small entities”

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking nearly 900 miles of the Appalachian Trail, and camping across the Chattahoochee, Pisgah, and Nantahala National Forests, has made plain to me what this proposal would put at risk. I strongly oppose revisions to the roadless rule that would open up more of these forests to motorized traffic. That expansion is not necessary for recreational or timber extraction reasons, and I am filing this comment to place that opposition in the federal record alongside the specific analytical failures the agency has not resolved. The Chattahoochee holds 23 inventoried roadless areas totaling 63,351 acres, including the wildest land in the southeastern United States at the southern end of the Appalachian chain, where black bears still roam and brook trout hold in the coldest headwater streams. The Nantahala holds 14 inventoried roadless areas totaling 52,304 acres and the Pisgah 18 areas totaling 99,369 acres, protecting the last wild headwaters of rivers that flow to both the Atlantic and the Gulf, along with salamander species found nowhere else on Earth. These are the forests through which I have moved on foot. Verified species across these landscapes include hellbender, cerulean warbler, the northern long-eared bat, more than 30 endemic salamander species, and brook trout, none of which will benefit from the road access this proposal enables. The rule I am asking the agency to retain has protected them, and it has protected the experience of encountering them without the intrusion of motorized traffic. The first problem in the supporting analysis is foundational. "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 certification is reached by spreading the expenditure loss across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The analysis then concedes that some of those firms may lose those receipts. A certification built on a national average, not on the businesses actually operating in places like the Chattahoochee, Nantahala, and Pisgah roadless areas, does not satisfy what the Regulatory Flexibility Act requires. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Second, the agency invited comment on reliance and then performed no assessment of what it received. "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 exactly such an interest. The Appalachian Trail passes through forests protected by the 2001 rule, and the nearly 900 miles I have walked along it represent a direct, concrete reliance on the character that rule has maintained. An agency changing course is obligated to identify and assess the reliance interests its prior policy created before it acts. The agency should identify and weigh the reliance interests described in the comments it receives, including this one. Third, the agency's own fire data argues against the proposal 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 then concedes that road access could increase the number and frequency of wildfires. That is a nearly eightfold difference in ignition density between roaded and roadless land, and the agency has not translated it into a projected increase tied to this specific proposal. How can the agency claim a net wildfire benefit while declining to quantify the expected increase in human-caused ignitions that its own data show follow from road construction? The forests I have walked through, the brook trout streams and salamander hollows of the Southern Appalachians, deserve better analysis than this proposal provides. I urge the agency to retain the 2001 Roadless Area Conservation Rule without rescission. Sincerely, Ren and Helen Davis Brookhaven, GA 30319 [Your City, State]