Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603759

Opposes rescissionA2 moderateSubstance 8/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding water quality protection, wildfire ignition quantification, and the regulatory flexibility analysis for small entities, while citing specific data from the DEIS and requesting the agency to identify funding sources and weigh reliance interests.

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

Water Quality Quantity
- “Clean water is life”
- “More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “protecting the water quality those watersheds provide”
Recreation Tourism Public Use
- “The peace I find away from human development”
- “My son loves to hike and camp”
- “Future generations deserve the same access to wilderness”
- “lost recreation benefit at a minimum of $6.1 million a year”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
- “The agency has not quantified the expected increase in human-caused ignitions”
Environmental Protection Biodiversity
- “show my son the beauty of nature”
- “build roads in our last remaining wild places”
- “Species besides humans deserve respect and dignity”
- “Plants and animals deserve protection from human development”

What it names

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 gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The peace I find away from human development, and the chance to show my son the beauty of nature, is exactly what would be lost if this administration guts the 2001 Roadless Area Conservation Rule. I am filing this comment in opposition to the proposed rescission under Docket FS-2025-0001. I take it on faith that so-called leaders are supposed to work for the public, not corporate interests. That faith has been tested here. The agency held more than 600 public meetings and took 1.6 million comments to write the rule it now proposes to undo. It has held none to undo it. I cannot imagine many support this initiative to build roads in our last remaining wild places besides those who profit from building these roads and logging these rare and sacred spaces. I ask that the agency value the voices of the people, not the voices of consumption and profit. The fiscal logic of this proposal fails on its face. The agency's own data show that "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." It makes no sense to build more roads when we already cannot maintain the ones we have. The DEIS states that road mileage, deferred maintenance and management costs are likely to increase under the proposal. I ask the agency to name the funding source for new road construction and maintenance and to state the projected change in that backlog. Clean water is life. More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas, and the agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. We must protect the very things that allow us to live on this earth. The agency has not explained how opening these last unroaded forests to road construction is consistent with protecting the water quality those watersheds provide. I expect a direct answer to that question in the final record. My son loves to hike and camp. Future generations deserve the same access to wilderness that past generations have enjoyed. Species besides humans deserve respect and dignity. Plants and animals deserve protection from human development. They are living beings, and their fate is bound up with these unroaded landscapes. The agency's economic certification ignores both of these realities. "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." The regulatory flexibility analysis reaches its no-impact conclusion by spreading the expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas. The agency must withdraw that certification and assess the impact on the small entities actually operating in these roadless areas. Forests are our lungs. The agency's own fire record makes the case for keeping them intact. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis itself concedes that road access could increase the number and frequency of wildfires. The agency has not quantified the expected increase in human-caused ignitions that new road access would bring, nor has it weighed that increase against the claimed reduction in wildfire hazard. That gap must be filled before any final decision is made. Finally, "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." This comment is one such interest. The expectation that these lands would remain unroaded has shaped how people like me think about what we can share with our children. An agency changing course must assess the reliance interests its prior policy created. I ask that the agency identify and weigh every reliance interest described in the comments it receives, including this one, before it proceeds further. Sincerely, Abbi Surles Bloomington, IN