Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601467

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS fails to quantify the increase in human-caused ignitions from new roads, does not apply the cited 13-75% biodiversity loss range to the 40.1 million acres of affected land, relies on national averaging to certify no significant impact on small businesses despite specific local losses, and fails to weigh the reliance interests solicited in the Federal Register notice.

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

Recreation Tourism Public Use
- “hiked, camped, and backpacked in them”
- “paddle as far away as I can get from crowds, industrial noise, logging scars”
- “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”
- “quantify the expected increase in human-caused ignitions from new road access”
- “weigh it plainly against the claimed wildfire benefit”
Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “apply the cited fragmentation range to the 40.1 million acres of potentially affected environment”
- “A logged stand can grow back. A road does not.”
- “These are the last unroaded third of the national forests”
Governance Policy Process
- “The agency is already billions of dollars behind on maintaining the roads it has”
- “developed through more than 600 public meetings and 1.6 million public comments”
- “No comparable public process has been held to undo it”
- “identify and weigh the reliance interests described in the comments”

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 Roadless areas have been a critical part of my life. I have hiked, camped, and backpacked in them across the Midwest, Southwest, Rockies, and West Coast. I paddle as far away as I can get from crowds, industrial noise, logging scars, and other effects of roads. That experience is not incidental to who I am, and I want my child to have that option. Rescinding the 2001 Roadless Area Conservation Rule would foreclose it. I oppose this proposal and ask that the agency address the following points in the record. The agency's own fire data does not support the direction it is moving. "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." That contrast is striking. The DEIS concedes that road access could increase the number and frequency of wildfires, yet no estimate of the expected increase in ignitions from new road construction is placed alongside the claimed reduction in wildfire hazard. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it plainly against the claimed wildfire benefit. The fragmentation problem is named but never applied. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and then disappears. No projection across the 40.1 million acres of potentially affected environment follows from it. A number cited and then set aside is not analysis. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment before this proposal advances further. I also cannot accept the agency's certification that this rule would have no significant impact on small businesses. "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 supporting analysis reaches its no-impact conclusion by averaging losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the areas that would be opened to roads. The analysis itself concedes some firms may lose these receipts. That is not a finding of no significant impact; it is a finding that impact is hidden by averaging. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. My reliance on these areas is the kind of interest the agency invited and has not weighed. "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." I have built my outdoor life around these places in the expectation that they would remain protected. My child's opportunity to do the same rests on the same assumption. The agency asked for these interests and then did not account for them. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Finally, I would not want my tax dollars wasted on new roads in these areas under any circumstances, but the fiscal case against this proposal is especially clear. The agency is already billions of dollars behind on maintaining the roads it has. Building new roads into country that currently has none compounds a deficit the agency has no realistic plan to close. The rule the agency proposes to rescind was developed through more than 600 public meetings and 1.6 million public comments. No comparable public process has been held to undo it. These are the last unroaded third of the national forests. A logged stand can grow back. A road does not. The agency has not explained why the public should accept that loss without the same opportunity to be heard that produced the original rule. Sincerely, David Clark Berkeley, CA