Comment Analysis · Docket FS-2025-0001

FS-2025-0001-600148

Opposes rescissionPosted October 7, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

Wildlife Habitat
- “wild turkey depends on exactly the kind of habitat roadless areas preserve”
- “complex forest structure with mast-producing trees”
- “sage grouse show strong site fidelity that limits how far they can adapt”
- “Opening roadless areas to road construction and timber harvest degrades that structure”
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”
- “quantify the expected increase in human-caused ignitions from new road access”
Governance Policy Process
- “reliance interests in the current rule that could be affected by this proposal”
- “change of course requires genuine engagement with what people and businesses built around the prior policy”
- “structured its analysis to avoid examining what will actually follow from rescission”
- “foreseeable plan-amendment scenario... belongs inside it”
Recreation Tourism Public Use
- “My family hikes and camps all over the country”
- “The beauty of untouched nature is something I believe should be valued and protected”
- “My family's use of these lands”
- “expectation that untouched nature would remain protected”

The comment

re:%20Rescission%20of%20the%20Roadless%20Area%20Conservation%20Rule,%20Docket%20FS-2025-0001%0A%0AMy%20family%20hikes%20and%20camps%20all%20over%20the%20country,%20and%20in%20my%20state%20I%20go%20looking%20for%20fox,%20owl,%20and%20wild%20turkey.%20The%20beauty%20of%20untouched%20nature%20is%20something%20I%20believe%20should%20be%20valued%20and%20protected.%20The%20proposed%20rescission%20of%20the%202001%20Roadless%20Area%20Conservation%20Rule%20threatens%20both,%20and%20I%20ask%20the%20agency%20to%20answer%20the%20specific%20concerns%20below.%0A%0AThe%20wild%20turkey%20I%20look%20for%20depends%20on%20exactly%20the%20kind%20of%20habitat%20roadless%20areas%20preserve.%20The%20DEIS%20names%20wild%20turkey%20and%20ruffed%20grouse%20among%20the%20game%20that%20needs%20complex%20forest%20structure%20with%20mast-producing%20trees,%20and%20notes%20sage%20grouse%20show%20strong%20site%20fidelity%20that%20limits%20how%20far%20they%20can%20adapt%20when%20habitat%20changes.%20Opening%20roadless%20areas%20to%20road%20construction%20and%20timber%20harvest%20degrades%20that%20structure.%20The%20agency%20has%20not%20explained%20how%20it%20will%20protect%20these%20upland%20species%20once%20that%20protection%20is%20removed,%20and%20I%20ask%20it%20to%20do%20so%20on%20the%20record.%0A%0AThe%20agency's%20own%20invitation%20on%20reliance%20interests%20goes%20unanswered%20in%20its%20economic%20work.%20The%20proposal%20solicits%20%22any%20reliance%20interests%20in%20the%20current%20rule%20that%20could%20be%20affected%20by%20this%20proposal%22%20(91%20FR%2053830-31),%20and%20the%20Cost%20Benefit%20Analysis%20weighs%20none.%20My%20family's%20use%20of%20these%20lands,%20and%20the%20expectation%20that%20untouched%20nature%20would%20remain%20protected%20under%20a%20rule%20in%20place%20for%20more%20than%20two%20decades,%20is%20exactly%20the%20kind%20of%20reliance%20interest%20that%20matters%20here.%20Under%20the%20administrative%20law%20principles%20that%20govern%20agency%20reversals,%20a%20change%20of%20course%20requires%20genuine%20engagement%20with%20what%20people%20and%20businesses%20built%20around%20the%20prior%20policy.%20I%20ask%20that%20the%20agency%20identify%20and%20weigh%20the%20reliance%20interests%20described%20in%20the%20comments%20it%20receives,%20including%20this%20one.%0A%0AThe%20agency's%20fire%20analysis%20points%20away%20from%20its%20own%20conclusion.%20Human-caused%20ignition%20density%20is%2022.4%20fires%20per%20million%20acres%20per%20year%20on%20roaded%20National%20Forest%20System%20land%20against%203.0%20inside%20the%20affected%20roadless%20areas%20(DEIS%20Table%2021,%202014-2024),%20and%20the%20DEIS%20states%20that%20human-caused%20ignitions%20increase%20in%20abundance%20with%20proximity%20to%20roads.%20The%20effects%20analysis%20itself%20concedes%20that%20road%20access%20could%20increase%20the%20number%20and%20frequency%20of%20wildfires.%20The%20agency%20claims%20the%20rescission%20will%20reduce%20wildfire%20hazard,%20but%20its%20own%20data%20suggest%20road%20access%20moves%20the%20ignition%20rate%20sharply%20upward.%20The%20agency%20must%20quantify%20the%20expected%20increase%20in%20human-caused%20ignitions%20from%20new%20road%20access%20and%20weigh%20it%20against%20the%20claimed%20reduction%20in%20wildfire%20hazard%20before%20this%20rule%20can%20go%20forward.%0A%0AFinally,%20the%20agency%20has%20structured%20its%20analysis%20to%20avoid%20examining%20what%20will%20actually%20follow%20from%20rescission.%20The%20proposed%20rule%20concedes%20that%20subsequent%20land%20management%20plan%20amendments%20and%20revisions%20%22could%20increase%20the%20area%20where%20timber%20harvest%20and%20road%20construction%20would%20be%20allowed,%22%20declares%20changes%20to%20plans%20beyond%20the%20scope%20of%20the%20proposal,%20and%20then%20requests%20public%20comment%20on%20them%20(91%20FR%2053830).%20That%20is%20asking%20the%20public%20to%20assess%20consequences%20the%20agency%20has%20placed%20outside%20its%20own%20analysis.%20The%20foreseeable%20plan-amendment%20scenario,%20including%20the%20expansion%20of%20timber%20harvest%20area,%20is%20a%20direct%20and%20predictable%20result%20of%20this%20action%20and%20belongs%20inside%20it.%20The%20agency%20should%20analyse%20that%20scenario%20as%20part%20of%20this%20rulemaking,%20not%20defer%20it.%0A%0ASincerely,%0AChristina%20Nicolas%20%0ALouisville,%20KY