Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604051

Opposes rescissionA1 strongSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's cost-benefit analysis fails to account for long-term deferred maintenance costs and ecological benefits, citing 2001 Forest Service data on road backlogs, and requests a 50-year analysis horizon and retention of the 2001 Roadless 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 Evidence, 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.
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.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

Topics

Economic Impact Fiscal
- “shifts costs onto future generations”
- “backlog of about $8.4 billion in deferred maintenance”
- “Every new road becomes a maintenance obligation for decades”
- “long-term costs that would fall on future taxpayers”
Water Quality Quantity
- “growing pressure on water supplies”
- “supply clean water without treatment plants”
- “water treatment”
Recreation Tourism Public Use
- “recreation residence permit”
- “give people somewhere to get away from the noise of everyday life”
- “lost recreation value”
- “walk into a forest that is still whole”
Climate Carbon Storage
- “store carbon at no cost to taxpayers”
- “long-term assets the public owns”

What it names

Law cited: 36 CFR 294.12(b)(1)36 CFR part 294 66 Fed. Reg. 3244

The comment

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

RE: Docket FS-2025-0001, RIN 0596-AD66, Special Areas; Roadless Area Conservation Introduction I am in my forties, which means I am among the people who will live longest with the outcome of this rulemaking. My family has held a recreation residence permit on a national forest since the 1930s. The cabin and the forest around it have been passed through the generations before me, and I hope to pass the experience of that forest on to the generations after me. I am commenting on how the proposed rescission of 36 CFR part 294, subpart B shifts costs onto future generations. What I am commenting on My comment addresses the cost and benefit analysis, especially the long-term costs that would fall on future taxpayers and forest users. Analysis My generation is inheriting many bills: aging infrastructure, more severe fire seasons, and growing pressure on water supplies. This proposal would add to them. In 2001 the Forest Service reported a backlog of about $8.4 billion in deferred maintenance and reconstruction on more than 386,000 miles of existing roads (66 Fed. Reg. 3244, Jan. 12, 2001). Every new road becomes a maintenance obligation for decades, long after any timber revenue has been spent. Those future costs should be counted in today's analysis, not left for later budgets. At the same time, roadless areas are among the best long-term assets the public owns. They supply clean water without treatment plants, store carbon at no cost to taxpayers, shelter fish and wildlife, and give people somewhere to get away from the noise of everyday life. These benefits continue year after year. A road, by contrast, is a one-way door. Once an area is roaded and logged, it does not return to its earlier condition in my lifetime or my children's. The existing rule already allows the agency to fight fires, reduce fuels, and build roads where public safety requires it (36 CFR 294.12(b)(1) and 294.13(b)(1)). Rescinding it does not give the agency a tool it lacks. It only removes the safeguard. I ask the agency to use a long time horizon in its analysis. A short horizon makes timber revenue look large and long-term losses look small. A fifty-year view would show the true balance. Recommendations 1. Select the no-action alternative and retain 36 CFR part 294, subpart B. 2. Evaluate costs and benefits over at least fifty years, including road maintenance, water treatment, fire suppression, and lost recreation value. 3. Disclose who will pay the long-term maintenance costs for any new roads and how those costs will be funded. Conclusion I want the people who come after me to have the same chance I had: to walk into a forest that is still whole. Please keep the 2001 Roadless Rule.