Comment Analysis · Docket FS-2025-0001

FS-2025-0001-602467

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's analysis fails to demonstrate sufficient benefits to justify rescinding the 2001 Roadless Area Conservation Rule, specifically citing modest revenue estimates, deferred analysis of foreseeable management responses, and inadequate quantification of carbon and climate consequences, while urging the selection of the No Action alternative.

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

A3 weak: Substantive, but easier to set aside.

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.
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.
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.
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

Climate Carbon Storage
- “non-market values such as carbon storage”
- “Intact roadless forests store carbon and provide ecological resilience”
- “Additional road construction and timber harvest can reduce stored carbon”
- “This is not the time for us to ignore the climate crisis”
Water Quality Quantity
- “non-market values such as... water quality”
- “effects on... water quality”
- “USDA should analyze a reasonable range of foreseeable management responses, including effects on... water quality”
Wildlife Habitat
- “non-market values such as... wildlife habitat”
- “effects on... wildlife habitat”
- “USDA should analyze a reasonable range of foreseeable management responses, including effects on... wildlife habitat”
Tribal Sovereignty
- “require the public and Tribal governments to participate repeatedly”
- “most Tribal governments it consulted oppose rescission”
- “identified inadequate government-to-government consultation as a central concern”
- “USDA should complete meaningful Tribal consultation”

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeAnalytical gapEvidenceRequestAlternativeLegal

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66) and urge USDA to select the No Action alternative. The agency's own analysis does not demonstrate benefits sufficient to justify eliminating nationwide protections. USDA estimates that if annual timber harvest occurred across all identified operable areas—a scenario the agency itself describes as unlikely because of budget, operability, and market constraints—the resulting revenue to the Treasury and Forest Service would be approximately $5.2–$11.4 million per year. At the same time, USDA estimates approximately $6.1 million per year in lost economic benefits to recreationists. The agency further acknowledges that potential management efficiencies would be incremental and constrained by road costs, maintenance funding, and other limitations. Removing national protections from tens of millions of acres should not rest on benefits this modest and uncertain. USDA should provide a transparent accounting of the reasonably expected costs and benefits of rescission, including non-market values such as carbon storage, water quality, wildlife habitat, scenery, and opportunities for quiet and remote recreation. Some of the most consequential reasonably foreseeable effects are deferred to future forest-plan and project-level decisions. Rescission would remove the national prohibitions that currently constrain road construction and timber harvest, while future forest-plan amendments could permit additional development within currently protected roadless areas. Those later decisions are central to understanding the practical consequences of rescission. USDA should analyze a reasonable range of foreseeable management responses, including effects on carbon storage, wildlife habitat, water quality, road construction, and timber harvest, before making a final decision. A national conservation floor remains necessary. Colorado and Idaho developed state-specific roadless protections through extensive, state-focused processes, and the proposed rule appropriately leaves those protections in place. Elsewhere, rescission would shift responsibility to individual forest plans and subsequent amendments. That would fragment decisionmaking and require the public and Tribal governments to participate repeatedly in separate processes to preserve protections now supplied by a uniform national rule, while well-resourced commercial interests can sustain pressure across many forests at once. A nationwide baseline provides consistency while still allowing appropriate exceptions. Climate effects also deserve fuller analysis. Intact roadless forests store carbon and provide ecological resilience. Additional road construction and timber harvest can reduce stored carbon and affect future sequestration. The final EIS should quantify, to the extent reasonably possible, the carbon consequences of rescission under realistic management scenarios rather than limiting the analysis to the immediate regulatory act. This is not the time for us to ignore the climate crisis. Wildfire management does not require wholesale rescission. The existing rule does not categorically prohibit hazardous-fuels treatment, although USDA has identified circumstances in which its restrictions can constrain mechanical treatment or suppression. If particular restrictions impede necessary work near communities or critical infrastructure, USDA should evaluate narrower amendments or streamlined exceptions targeted to those circumstances, without removing protections from remote backcountry. USDA should also account for its own acknowledgment that increased road access can increase human-caused ignitions. The rulemaking process also raises concerns. USDA reports receiving more than 220,000 comment letters on behalf of over 625,000 individuals and organizations during scoping, and independent tallies indicate the overwhelming majority opposed rescission. USDA also reports that most Tribal governments it consulted oppose rescission and identified inadequate government-to-government consultation as a central concern. Before final action, USDA should complete meaningful Tribal consultation and provide additional opportunities for public participation. For these reasons, I urge USDA to withdraw the proposed rescission and select the No Action alternative, retaining the 2001 Roadless Area Conservation Rule. Seattle, WA Bruno