Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603290

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

In short: The comment documents specific deficiencies in the DEIS and Cost Benefit Analysis regarding unquantified sediment delivery, lack of enforceable drinking water protections, unreconciled maintenance shortfalls, and excluded costs in the economic analysis, while requesting specific quantitative responses and the inclusion of an alternative retaining the 2001 rule.

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, 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

Water Quality Quantity
- “Road sediment is quantified and then set aside”
- “Twenty-four million people's drinking water is asserted away”
- “Unmaintained roads damage water, by the agency's own admission”
- “Lack of maintenance commonly has detrimental effects on water quality”
Economic Impact Fiscal
- “The agency cannot afford the roads it already has”
- “deferred maintenance backlog of $6.9 billion for roads and bridges”
- “net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million”
- “I care how my tax money gets spent”
Governance Policy Process
- “ask that the agency respond to each of them”
- “I ask that the agency place the Cost Benefit Analysis on the docket”
- “provide a reasoned explanation for it on the record”
- “analyze in the DEIS an alternative that retains the 2001 rule's protections”

What it names

Law cited: 36 CFR 294.12
Works cited: Furniss et al. 1991

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Road sediment is quantified and then set aside I paddle water that starts in this country, and clean, free-running rivers are the whole reason I go. What roads send into a watershed lands directly on people like me. The DEIS: skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." The number appears in the document; no projection of sediment delivery follows it. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. Issue 2: Twenty-four million people's drinking water is asserted away I paddle rivers that begin in these forests, and I am downstream of every decision made above them. That is why I raise what this proposal means for drinking water. Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired. The DEIS says forest plans address sources of public drinking water without identifying one enforceable provision. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. Issue 3: Unmaintained roads damage water, by the agency's own admission As a paddler I live with whatever a watershed sheds. A road nobody can afford to maintain fails into the river, and the agency admits as much in its own words. "Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance." The same document proposes adding road mileage against a maintenance shortfall it identifies as a cause of water quality damage. I ask that the agency reconcile the proposed increase in road mileage with the maintenance shortfall its own analysis identifies as a water quality cause. Issue 4: The agency cannot afford the roads it already has This is my money. Before the agency commits to building more, I want it to account for what it already cannot maintain. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring. The DEIS states that road mileage, deferred maintenance and management costs are likely to increase under the proposal. I ask that the agency name the funding source for new road construction and maintenance and state the projected change in the backlog. Issue 5: The agency's own accounting cannot say if this makes money or loses it I care how my tax money gets spent, and I expect an honest accounting before public assets are traded away. The agency's own analysis cannot provide one. The Cost Benefit Analysis: "the net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million (-$70 to $152 million discounted at 7 percent) and uses maximum potential costs and benefits that do not account for uncertainty." The cost column excludes the road construction ($80,000 to $100,000 per mile, roughly $500,000 per mile in Alaska), maintenance and fuel treatment costs the same document quantifies, and the upper bound assumes maximum potential harvest the analysis itself calls uncertain. An economically significant rule whose own analysis spans from a $92 million loss to a $199 million gain has not shown a benefit; the analysis was published in an agency file folder rather than on the docket, and the rule's claim that impacts "could exceed $100 million" (91 FR 53830) appears with no arithmetic anywhere, though every quantified annual line item is under $22 million. I ask that the agency place the Cost Benefit Analysis on the docket, restate the net present value with its own quantified road and fuels costs included in the cost column, and show the arithmetic behind the statement that impacts could exceed $100 million. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Amy Ball