Comment Analysis · Docket FS-2025-0001

FS-2025-0001-602747

Opposes rescissionA1 strongSubstance 12/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Area Conservation Rule contradicts its own DEIS findings regarding fire ignition rates on roaded lands, documented declines in bird abundance due to road noise, and economic analyses showing no net benefit, while failing to identify specific permitting burdens or properly assess impacts on small entities.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Environmental Protection Biodiversity
- “bird richness declines with road presence”
- “road-noise experiments... cut bird abundance by over a quarter”
- “31 percent of species avoiding the noise entirely”
- “documented harm to bird communities”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “More people and machines in these areas means more opportunities for fires to start”
- “far higher fire density on roaded land than inside the affected roadless areas”
- “reconcile the rescission with the ignition data”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year”
- “road system already carrying a $6.9 billion maintenance backlog”
- “economic analysis that cannot establish a net benefit”
Recreation Tourism Public Use
- “scale of wilderness I have encountered while camping and hiking”
- “vast an area existed beyond the trails, stretching out untouched”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides and tour operators as affected”

What it names

Law cited: 36 C.F.R. Section 294.12
Works cited: Kroeger et al. 2022

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 The scale of wilderness I have encountered while camping and hiking in national parks has never stopped surprising me. In each place, what struck me most was how vast an area existed beyond the trails, stretching out untouched. Those huge wilderness areas need to continue to exist without the roads and extraction industries now being proposed. Rescinding the Roadless Area Conservation Rule would end that. The wildfire argument the agency offers for rescission is directly contradicted by the agency's own findings. I noticed years ago that most wildland fires are caused by humans, and the record confirms it. The agency's own text states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." More people and machines in these areas means more opportunities for fires to start. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement (DEIS Table 21), which reports far higher fire density on roaded land than inside the affected roadless areas. I always have my camera when I am hiking. Landscapes, wildflowers, rocks, birds, and wild animals (if I am lucky enough to encounter them): I photograph them. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely, drawing on Kroeger et al. 2022, McClure et al. 2013, and Ware et al. The agency entered these findings into its own record and then proposed to open these areas to exactly the disturbances that produce those outcomes. The agency should explain how it weighs that documented harm to bird communities against whatever benefits it claims to project. The economic case for rescission is similarly hard to sustain from the agency's own numbers. The record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal gain, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, a net present value spanning -$92 million to +$199 million, and a road system already carrying a $6.9 billion maintenance backlog. The agency must reconcile the proposal with an economic analysis that cannot establish a net benefit on its own terms. The permitting burden rationale fares no better. The rule as written already states that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Exceptions for existing mineral leases and community wildfire protection are also part of the existing framework. The agency has not identified which specific burdens fall outside those provisions. It should do so, with numbers, before proceeding. Finally, the regulatory flexibility certification does not hold together. 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 was reached by spreading a projected expenditure loss across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The agency should withdraw that certification and conduct the assessment on the firms actually at risk, not a national average. Sincerely, Charleen Boudreau Illinois