Comment Analysis · Docket FS-2025-0001

FS-2025-0001-602829

Opposes rescissionA2 moderateSubstance 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 is internally inconsistent with its own DEIS data on wildfire ignition rates and road maintenance backlogs, and that the economic and small-business impact analyses are misleading due to national averaging and failure to identify specific operational needs outside existing exceptions.

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

Environmental Protection Biodiversity
- “what makes roadless country irreplaceable is precisely the absence of exploitation and intervention”
- “Once a road goes in, the prior state cannot be recovered”
- “Keep it Wild”
- “irretrievable values at risk”
Forest Management Wildfire
- “roads allow more agile positioning of firefighting assets, they are also the site of high rates of human-caused ignition”
- “far higher fire density on roaded land than inside affected roadless areas”
- “reconcile the rescission with the ignition data in its own DEIS Table 21”
- “community wildfire protection”
Water Quality Quantity
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
- “rely on intact headwaters”
- “degraded source water that road construction accelerates”
- “sedimentation or degraded source water”
Economic Impact Fiscal
- “net present value spanning -$92 million to +$199 million”
- “recreation losses of at least $6.1 million a year”
- “agency is already carrying a $6.9 billion road maintenance backlog”
- “creation of an expanded opportunity economy for the wealthy at the expense of people who lead simpler, more meager lives”

What it names

Works cited: Narayanaraj and Wimberly 2012

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 Every year hiking with my dad in wilderness areas has shown me something that no policy brief can teach: what makes roadless country irreplaceable is precisely the absence of exploitation and intervention. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. These places can be reached by hunters, by anglers, by conservation enthusiasts, by campers, but only through effort, and that effort is part of what they are. Once a road goes in, the prior state cannot be recovered. Keep it Wild. The proposal justifies rescission in part on wildfire and fuels management grounds, but the agency's own record undercuts that argument. The DEIS states: "While roads allow more agile positioning of firefighting assets, they are also the site of high rates of human-caused ignition (Narayanaraj and Wimberly 2012), which account for 84% of US wildfires (Balch et al 2017)." The agency's own data show far higher fire density on roaded land than inside affected roadless areas. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it reconcile the rescission with the ignition data in its own DEIS Table 21. The economic case does not hold together either. The agency's own record acknowledges 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, 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, with a net present value spanning -$92 million to +$199 million. I object to the creation of an expanded opportunity economy for the wealthy at the expense of people who lead simpler, more meager lives and just want a few patches of nature to enjoy. Decisions of this kind are not making fiscal sense, particularly when the agency is already carrying a $6.9 billion road maintenance backlog on a budget of roughly $73 million a year. The agency must explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system the agency already cannot maintain. The proposal also claims the rule imposes administrative burdens, but the agency's own analysis of the existing rule states: "It makes little fiscal or environmental sense to build additional roads in inventoried roadless areas that have irretrievable values at risk when the agency is struggling to maintain its existing extensive road system (FEIS Vol. 1, 1-5 and 3-22)." The rule as written already contains exceptions for public health and safety, existing mineral leases, and community wildfire protection. The agency has not identified which specific operational needs fall outside those existing exceptions. I ask that it do so, and that it quantify those burdens on the record rather than assert them. Across the Pacific Northwest region, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The communities drawing from those watersheds include people who are not wealthy, who rely on intact headwaters, and who are not positioned to absorb costs from sedimentation or degraded source water that road construction accelerates. The small-business certification that accompanies this proposal reaches its no-impact conclusion by spreading estimated losses across every small firm in the sector nationally rather than examining the outfitters, guides, and tour operators actually holding permits in the affected areas. The agency concedes that some of those firms may lose those receipts. Spreading a real local loss across a national average does not make the loss disappear; it makes the analysis misleading. The agency should withdraw the certification and conduct a genuine assessment of the small entities actually operating in the potentially affected roadless areas. The rule the agency proposes to rescind was built on more than 600 public meetings and 1.6 million comments. No comparable process has been offered for its undoing. There are things worth preserving so that future generations can connect with the historical experiences of Americans who long preceded them. The proponents of this rescission can find their wealth opportunities elsewhere. I ask that the agency address each of these points in the final record. Sincerely, A.M.C. Washington, DC