Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603153

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the DEIS identifies a $7 billion deferred maintenance backlog and insufficient revenue to fund new roads, while simultaneously projecting that rescinding the Roadless Rule will increase wildfire risk, degrade water and air quality, harm over 300 listed species in violation of the ESA, and result in a net economic loss compared to recreation revenue.

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.

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

Forest Management Wildfire
- “rescinding the roadless rule will NOT meaningfully decrease wildfire risk”
- “incidence of human-caused fires generally increases with proximity to roads”
- “timber projects are the primary motivation and funding source for new roads”
Water Quality Quantity
- “7,000 municipal water intakes within watersheds in designated roadless areas”
- “water quality will be degraded by the addition of new roads”
- “increasing sediment and nutrient runoff into streams”
Wildlife Habitat
- “overlap the range of more than 300 threatened, endangered, and proposed species”
- “habitat loss and degradation”
- “introduction and spread of non-native and invasive species”
Economic Impact Fiscal
- “recreation and tourism are more profitable than roadless timber”
- “visitors to roadless areas spend $8.5 billion total in local communities”
- “timber harvest value in 2024 across ALL national forest land was just $151 million”

What it names

National Forests: Chattahoochee National Forest Nantahala National Forest
Roadless areas: Smoky Mountains

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestLegal

I am an Environmental Engineer in the state of Georgia, currently employed in a regulatory field. The roadless areas closest to me are in the Chattahoochee National Forest, the Nantahala National Forest, and the Great Smoky Mountains. I spend a considerable amount of time recreating in these areas on my weekends and off hours. I have also taken trips across the country and recreated in roadless areas in Washington and California. I have experienced firsthand the beauty and value of these areas, and wish to highlight the importance in conserving them. I am writing this comment to oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. According to the USDA Forest Service's own assessment, rescinding the roadless rule will NOT meaningfully decrease wildfire risk - it is actually more likely to INCREASE wildfire risk. Page 86 of the DEIS report states: "the incidence of human-caused fires generally increases with proximity to roads." Additionally, there is already an exception in the existing Rule for cutting and removing small timber as a means of reducing wildfire risk. Page 102 of the DEIS states that "timber projects are the primary motivation and funding source for new roads", NOT reducing wildfire risk. However, the Forest Service already lacks the budget to maintain its existing roads and infrastructure, with a current deferred maintenance backlog of $7 billion. The DEIS states, on page 45: "revenue generated by timber sales or other...activities would be used for some road-related system management but would not be sufficient to cover the costs of constructing and maintaining all new roads related to a project." So where is the money needed to build these proposed new roads, at an estimated cost of $2 million per mile (as stated in page 42 of the DEIS), coming from? Rescinding the Roadless Rule will have negative impacts on soil, water, and air quality. Increased timber harvests will increase soil erosion, compaction, and landslide probability. Page 120 of the DEIS states that there are 7,000 municipal water intakes within watersheds in designated roadless areas, supplying water to nearly 5 million people just within the Pacific Southwest. Water quality will be degraded by the addition of new roads, as roading and timber harvest degrade water quality by increasing sediment and nutrient runoff into streams, creating warmer and hypoxic conditions (page 117, DEIS). Removing tree canopies will alter the timing of spring snowmelt and runoff. Increases in timber harvest will also result in increased emissions from trucks and other equipment (page 128, DEIS). Page 160 of the report states that roadless areas "overlap the range of more than 300 threatened, endangered, and proposed species, 79 final or proposed critical habitats managed by the USFWS, and 19 critical habitats...listed under the ESA". The DEIS projects negative impacts that include habitat loss and degradation, introduction and spread of non-native and invasive species, increased human-wildlife conflict, and detrimental impacts to fish and game species. (Pages 142, 151, 152) Though the current administration is waging a war against the Endangered Species Act, the USFS IS CURRENTLY STILL REQUIRED to comply with the ESA. It is unclear how the USFS plans to do so when its own report states that rescinding the Roadless Rule will directly lead to noncompliance with the ESA. Circling back to the financial questions posed in the second paragraph, it is known that recreation and tourism are more profitable than roadless timber. In 2024, visitors to roadless areas spend $8.5 billion total in local communities (DEIS page 212). Meanwhile, timber harvest value in 2024 across ALL national forest land was just $151 million (DEIS page 220). Roadless timber is only expected to generate $2.2-$11.4 million dollars annually (DEIS page 220). Even a 1% loss in visitation to roadless areas due to rescission of this rule could lead to a projected loss of $9 million annually. So again I ask, who stands to profit from these timber harvests? Seemingly not the USFS, since we have covered that profits from timber harvests will not be enough to cover the costs of building the roads required for such projects, and likely not the local economies poised to lose millions tourism dollars either. If there is no clear benefit, financial or otherwise, to increased timber harvests, then why is it being proposed? Who stands to benefit? In the current era of constant threats to our natural environment and the health and financial wellbeing of the American people, we must place the highest importance on protecting and conserving what natural resources we have left. Due to the financial concerns and projected negative impacts on wildfire risk, soil quality, water quality, air quality, biodiversity, recreation, and tourism as outlined above, I must oppose the recission of the Roadless Rule, and urge all others to do the same.