Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603820

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment places on the record specific financial data from the 2001 FEIS and DEIS demonstrating that the deferred maintenance backlog and negative net present value of road construction outweigh projected timber revenues, while highlighting the procedural asymmetry of rescinding a rule based on 1.6 million comments without equivalent public engagement.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on 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.
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.
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.
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

Economic Impact Fiscal
- “drain on taxpayers”
- “deferred-maintenance road backlog was estimated at $8.4 billion”
- “net present value that runs to negative $92 million”
Environmental Protection Biodiversity
- “The wildlife, the habitat, the carbon, the character of these places”
- “these are not recoverable once the decision is made”
- “irreversible act”
Governance Policy Process
- “held more than 600 public meetings and took 1.6 million comments”
- “It has held none to undo it”
- “That asymmetry alone should give the agency pause”

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequest

I am writing to oppose the rescission of the 2001 Roadless Area Conservation Rule. Rescinding it would be an irreversible act, and a shameful one. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a $6.9 billion deferred maintenance backlog. The supplemental funding is expiring. Maximum projected timber revenue is $5.2 to 11.4 million a year, against up to $6.1 million a year in lost recreation benefit by its own figures, and the agency’s own cost-benefit analysis states a net present value that runs to negative $92 million. The DEIS states outright that road mileage, deferred maintenance and management costs are likely to increase. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. That asymmetry alone should give the agency pause. What is built can sometimes be corrected. A road through a roadless landscape cannot be unbuilt. The wildlife, the habitat, the carbon, the character of these places: these are not recoverable once the decision is made. I want this record to show that the agency was told so, and I want it to show what the agency intends to do about every specific deficiency named here.