Comment Analysis · Docket FS-2025-0001

FS-2025-0001-600374

Opposes rescissionA0 noneSubstance 11/24Posted October 7, 2026 On Regulations.gov

In short: The comment documents the economic disparity between recreation spending and timber revenue in roadless areas, cites specific DEIS data regarding wildfire ignition densities, road maintenance backlogs, water intake locations, and species overlaps, and requests the retention of the Roadless Rule and an extended public comment period.

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

A0 none: Counted, not answered.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Recreation Tourism Public Use
- “photographs proposals and elopements in the backcountry”
- “quiet, intact wild places”
- “Visitors to roadless areas spent $8.5 billion”
- “skiing, hiking, mountain biking, paddleboarding, river rafting, wildlife viewing, stargazing, and foraging”
Economic Impact Fiscal
- “The economics don't add up”
- “timber from these areas is projected to generate just $2.2 to $11.4 million a year”
- “Small businesses like mine would pay for a harvest that earns far less than the recreation it displaces”
- “timber revenue wouldn't cover the cost of building and maintaining new roads”
Water Quality Quantity
- “Water and wildlife are at stake”
- “7,000 municipal water intakes sit in watersheds containing roadless areas”
- “landslides are 6 to 9 times more likely near forest roads”
Wildlife Habitat
- “lands overlap the range of more than 300 threatened, endangered, and proposed species”
- “Water and wildlife are at stake”

The comment

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

I oppose the proposal to rescind the Roadless Rule. I co-own a small photography business that photographs proposals and elopements in the backcountry. Our clients don't book us to stand beside a logging road. They come for quiet, intact wild places, and that landscape is the foundation of our livelihood. For 25 years, the Roadless Rule has given businesses like mine something rare: predictability. We can plan seasons, invest in this work, and promise couples these places will still be here. Rescinding the rule trades that lasting value for short-term flexibility. The economics don't add up. Visitors to roadless areas spent $8.5 billion in nearby communities in 2024 (DEIS p. 212), while timber from these areas is projected to generate just $2.2 to $11.4 million a year (p. 220). The DEIS itself notes that outfitters and guides may face higher costs (p. 224). Small businesses like mine would pay for a harvest that earns far less than the recreation it displaces. The wildfire rationale is thin. Per the DEIS, human-caused fires are a much smaller share of fires in roadless areas than elsewhere on national forest land, and ignition density is about four times higher on other lands (pp. 86, 89). The document also acknowledges that timber projects are the primary motivation and funding source for new roads (p. 102). That makes this look more like a timber policy than a fire policy. We can't maintain the roads we have. The Forest Service reports a $7 billion maintenance backlog, and fewer than 30% of its roads are in good condition (pp. 40, 42). The DEIS concedes timber revenue wouldn't cover the cost of building and maintaining new roads (p. 45). Water and wildlife are at stake. About 7,000 municipal water intakes sit in watersheds containing roadless areas (p. 120), and landslides are 6 to 9 times more likely near forest roads (p. 111). These lands overlap the range of more than 300 threatened, endangered, and proposed species (p. 160). Tribal interests deserve more than a promise. The DEIS acknowledges possible reduced access to treaty-reserved resources and sacred sites (pp. 201-202). Please keep the rule in place, and give the public a comment period equal to a decision affecting tens of millions of acres. These untouched areas are also where I spend my own time: skiing, hiking, mountain biking, paddleboarding, river rafting, wildlife viewing, stargazing, and foraging. It's incredibly important to me and to anyone else who recreates in these areas that they remain wild wilderness.