Comment Analysis · Docket FS-2025-0001

FS-2025-0001-600774

Opposes rescissionA2 moderateSubstance 17/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the DEIS fire data (Table 21) contradicts the proposal's claim that roads reduce fire risk, that the agency's $6.9 billion maintenance backlog undermines the fiscal feasibility of new roads, that the regulatory flexibility analysis improperly uses national averages to ignore local small entities and 286 municipal water intakes in Vermont, and that the NEPA alternatives analysis is compromised by a deregulatory purpose statement that excludes protective options and fails to weigh reliance interests.

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, Alternative.

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
- “exercise, tranquility, and connection to nature”
- “wildness, the quiet, the beauty that belongs to all people”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides and tour operators as affected”
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”
- “These numbers do not support the suggestion that new roads reduce fire risk”
- “quantify the expected increase in human-caused ignitions”
Legal Regulatory Framework
- “regulatory flexibility analysis does not survive scrutiny”
- “NEPA requires that comparison”
- “framing the purpose around executive orders rather than forest conditions forecloses it”
- “withdraw the no-impact certification”
Economic Impact Fiscal
- “The agency is $6.9 billion behind on maintaining the roads it already operates”
- “Building new roads into country that currently has none... creates a new liability”
- “money should go into improving those rather than paving over nature”
- “how it intends to fund the long-term upkeep of any roads”

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 The Green Mountains of Vermont and the White Mountains of New Hampshire are where I find exercise, tranquility, and connection to nature and the hiking community. I go there often, and what I find in those places, the wildness, the quiet, the beauty that belongs to all people, is exactly what this proposal would put at risk. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be entered into the docket record. Vermont holds 6 inventoried roadless areas totaling 25,096 acres. Those acres represent something that cannot be rebuilt once it is paved over. Public land should be managed for all people and protected so that the wild and beautiful spaces it contains remain available for everyone to enjoy. Rescinding the rule moves in the opposite direction, converting a national protection into a state-by-state patchwork where those spaces are only as safe as the next administrative decision. I ask that the agency address directly, in its final analysis, how rescission serves the public interest in retaining these spaces in their current condition. The agency's own fire data undercuts the case for opening these areas to road construction. The DEIS states that "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." These numbers do not support the suggestion that new roads reduce fire risk. They suggest the opposite. I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that figure honestly against whatever wildfire hazard reduction the proposal claims. The fiscal argument for this rescission is equally hard to square with reality. We already struggle to maintain the roads and infrastructure we have, and money should go into improving those rather than paving over nature. The agency is $6.9 billion behind on maintaining the roads it already operates, on a road budget of about $73 million a year. Building new roads into country that currently has none, under those conditions, is not a maintenance solution. It creates a new liability. The agency should explain, plainly and specifically, how it intends to fund the long-term upkeep of any roads built in areas currently protected by this rule. The regulatory flexibility analysis does not survive scrutiny. "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 conclusion is reached by spreading losses across every small firm in the sector nationally, rather than looking at the guides and outfitters who actually hold permits in the affected areas. The Eastern region, which includes Vermont, has 286 municipal water intakes sitting in watersheds that contain affected roadless areas, and the communities and businesses that depend on those watersheds deserve an honest local accounting, not a national average. The agency should withdraw the no-impact certification and assess the actual small entities operating in these specific areas. The alternatives analysis is compromised at its foundation. "Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it 'would continue to restrict local decision-making discretion' and because analysing roadless values is 'an administrative and legal burden for the agency.'" A purpose statement written to mandate deregulation cannot produce a genuine comparison of alternatives. NEPA requires that comparison, and framing the purpose around executive orders rather than forest conditions forecloses it before the analysis begins. The agency should restate the purpose and need in terms grounded in actual resource conditions and carry at least one genuinely protective alternative through a full effects analysis. Finally, the proposal invites reliance interests and then ignores them. "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 2001 rule has shaped how hikers, outfitters, water utilities, and communities have planned and invested for years. An agency changing course must assess those interests, not merely invite them. The agency should identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further.