Comment Analysis · Docket FS-2025-0001

FS-2025-0001-605024

Opposes rescissionA1 strongSubstance 11/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS and Cost Benefit Analysis contain internal contradictions regarding wildfire ignition risks and net economic benefits, and that the regulatory flexibility analysis fails to assess impacts on specific small entities in the affected areas, thereby undermining the justification for rescinding the Roadless Area Conservation 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, 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.
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

Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands”
- “Opening these areas to new roads does not reduce ignition risk. It multiplies it.”
Economic Impact Fiscal
- “the total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year”
- “The road system the agency proposes to expand already carries a $6.9 billion maintenance backlog”
Environmental Protection Biodiversity
- “Clean air, clean water, the smell of the earth and trees, the sound of silence, the sounds of nature, the great expanse untamed”
- “These untrammeled and unpaved lands must exist for our generation and for future generations”
- “My wish is for every creature to have a place called home where it can sustain a life without human conflict”
Legal Regulatory Framework
- “The agency must explain, in specific terms, why this proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas”
- “The regulatory flexibility analysis certifies no significant impact on small entities by spreading a $9 million annual expenditure loss across every small firm in the sector nationally”
- “The agency has not identified which specific burdens fall outside those provisions. It must do so, with numbers attached”

What it names

Law cited: 36 C.F.R. Section 294.12

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 Clean air, clean water, the smell of the earth and trees, the sound of silence, the sounds of nature, the great expanse untamed: these are medicine to the mind, body, and soul. These untrammeled and unpaved lands must exist for our generation and for future generations, because wilderness is what makes us, as humans, a part of this planet, whole. That conviction is why I oppose rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, without reservation. The agency's own record destroys the wildfire rationale at the center of this proposal. The DEIS states plainly: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Opening these areas to new roads does not reduce ignition risk. It multiplies it. The agency must explain, in specific terms, why this proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and it must reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case is no stronger. The agency's own analysis states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." These are the agency's numbers, not mine. The Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, and a net present value spanning -$92 million to +$199 million. The road system the agency proposes to expand already carries a $6.9 billion maintenance backlog. How does an action whose own analysis cannot establish a net benefit justify adding to that backlog? The agency must reconcile this proposal with those figures and answer that question on the record. I photograph the trees, running waters, the skies and the expanse, the critters and wildlife I encounter. Every photo is a precious memory and a gift of gratitude that such places exist. My wish is for every creature to have a place called home where it can sustain a life without human conflict. Outfitters, guides, and tour operators who bring people into these places share something of that purpose, and the DEIS names them directly as affected parties. Yet the regulatory flexibility analysis certifies no significant impact on small entities by spreading a $9 million annual expenditure loss across every small firm in the sector nationally, rather than examining the outfitters and guides actually holding permits in the areas at issue. The same analysis concedes some of those firms may lose those receipts entirely. The agency must withdraw that certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not a national average firm that has never set foot in them. Finally, the agency frames rescission as a solution to administrative burden, but the rule as written already accommodates the situations cited. It generally banned road building "subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Existing exceptions cover public health and safety, existing mineral leases, and community wildfire protection. The agency has not identified which specific burdens fall outside those provisions. It must do so, with numbers attached, before claiming the rule itself is the obstacle. These untrammeled places are what make us whole. The record assembled by the agency does not support taking them apart. I urge the agency to withdraw this proposal. Sincerely,