Comment Analysis · Docket FS-2025-0001

FS-2025-0001-593581

Opposes rescissionA1 strongSubstance 17/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's rescission proposal fails to quantify specific administrative burdens beyond existing exceptions, relies on a flawed national average for small-business impact assessment, ignores solicited reliance interests, and contradicts its own fire data regarding human-caused ignitions in the Tongass National Forest.

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

Climate Carbon Storage
- “roughly 44 percent of all the carbon stored by US national forests”
- “largest intact temperate rainforest left on Earth”
- “Tongass National Forest”
Wildlife Habitat
- “safe habitat for the brown bear, the Alexander Archipelago wolf, bald eagle”
- “five species of Pacific salmon, marbled murrelet, and the Sitka black-tailed deer”
- “12,930 miles of salmon-producing streams”
Legal Regulatory Framework
- “reliance interests created by prior policy must be identified and assessed”
- “small-business certification attached to this proposal”
- “regulatory flexibility analysis reaches its no-impact conclusion by spreading expenditure losses”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded NFS land against 3.0 inside the affected roadless areas”
- “new road access could increase the number and frequency of wildfires”
- “community wildfire protection”

What it names

National Forests: Tongass National Forest Tongass National Forest
Law cited: 36 C.F.R. Section 294.12 Executive Order 14153

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 Tongass National Forest in Ketchikan is where I hike with my Maremma Sheepdog, and it is the reason I oppose the rescission of the 2001 Roadless Area Conservation Rule. This forest, the largest intact temperate rainforest left on Earth according to the USFS, holds 9,339,575 acres across 110 inventoried roadless areas, over 12,930 miles of salmon-producing streams, and roughly 44 percent of all the carbon stored by US national forests. Executive Order 14153 directs the agency to expressly exclude Tongass National Forest from the 2001 Roadless Rule, and the Federal Register rescission notice confirms this in writing. Under both action alternatives Tongass National Forest keeps zero acres of roadless protection. I hike in a place that would be left entirely exposed, and I am asking the agency to answer several questions it has not yet answered adequately. The first is about the rule's own exceptions. The agency cites permitting and administrative burden as justification for rescission, but 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)." If the existing framework already accommodates public health and safety construction, existing mineral leases, and community wildfire protection, I do not understand what specific burden requires elimination of the rule rather than adjustment within it. I ask that the agency identify, with specificity, which administrative or permitting burdens fall outside what those existing exceptions already address, and that it quantify those burdens somewhere in the record. The second concerns the small-business certification attached to this proposal. "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." The Tongass National Forest supports guiding and outfitting operations that depend on the quality and character of roadless areas. The regulatory flexibility analysis reaches its no-impact conclusion by spreading expenditure losses across every small firm in the sector nationally rather than examining the firms that actually hold permits in the affected areas. That methodology produces a number that does not address the operators who would actually absorb the loss. I ask that the agency withdraw the current certification and replace it with an assessment of the small entities operating in the specific roadless areas at issue, specifically in the Tongass National Forest, not a national average. Third, the agency's own Federal Register notice 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. My decision to hike in the Tongass NF and my expectation that construction and extraction would remain constrained there, is exactly the kind of reliance interest the notice invited. Under the legal framework governing agency changes of course, reliance interests created by prior policy must be identified and assessed before that policy is reversed. I ask that the agency identify and weigh the reliance interests submitted in comments, including mine. Fourth, the agency's own fire data does not support the direction it is heading. "Human-caused ignition density is 22.4 fires per million acres per year on roaded NFS 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 Tongass watershed that serves Ketchikan is among the nine municipal watersheds named in the DEIS. The effects analysis itself concedes that new road access could increase the number and frequency of wildfires, yet the proposal treats road access as a tool for reducing wildfire hazard without resolving that contradiction. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against whatever wildfire reduction it claims, before this rescission can be treated as a reasoned decision. This space should continue to be protected from construction and extraction activities. The Tongass NF provides safe habitat for the brown bear, the Alexander Archipelago wolf, bald eagle, five species of Pacific salmon, marbled murrelet, and the Sitka black-tailed deer. Removing roadless protection from every acre of it, under both alternatives, leaves this treasured space without a structural safeguard. The agency has not answered any of the questions above in the materials it has released. I expect answers in the final record. Sincerely, Aurora Otto Ketchikan, Alaska