Comment Analysis · Docket FS-2025-0001

FS-2025-0001-605436

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment places on the record specific deficiencies in the agency's analysis, including the failure to project sediment delivery despite acknowledging high erosion rates, the failure to identify specific administrative burdens outside existing regulatory exceptions, and the contradiction between the proposed rescission and the agency's own data on wildfire ignition rates and net economic benefits.

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
- “cars covered in ash, wearing N95 masks”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “ignition data in DEIS Table 21”
Water Quality Quantity
- “reduction in natural salmon habitats”
- “removing riparian vegetation can raise stream temperatures”
- “skid roads... can contribute up to 90 percent of the sediment generated by timber sale activity”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year”
- “road system already carrying a $6.9 billion maintenance backlog”
Recreation Tourism Public Use
- “I fish rivers in Virginia and the Kenai River of Alaska”
- “I also ride and camp in the George Washington National Forest”
- “I often bird watch for pileated woodpeckers and Steller's jays”

What it names

National Forests: George Washington National Forest George Washington National Forest
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 Waking up to cars covered in ash, wearing N95 masks to school, being told to stay indoors: that is the reality I lived through during California's fire seasons, most of them ignited near a road line. Human-generated fires, from forest roads, shaped those years. That experience is why I cannot support rescinding the 2001 Roadless Area Conservation Rule, and why the agency's stated justifications for doing so upsets me as deeply as it does. The agency frames rescission partly as a wildfire management measure. Its own record says otherwise. The DEIS states: "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." I watched that dynamic play out with my own eyes across Tahoe, Big Sir and Yosemite, California. I ask that the agency explain why the proposal departs from this finding, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. I fish rivers in Virginia and the Kenai River of Alaska. After logging and other industrial projects, I have seen a reduction in natural salmon habitats and watched river banks erode away, taking homes with them. That observation tracks what the agency's own documents record. The DEIS notes that removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and that warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, in areas that include Essential Fish Habitat and critical habitats managed by NMFS. Virginia holds 64 inventoried roadless areas totaling 393,682 acres, and across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own DEIS states that 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." That number appears in the document and then 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 before any final action is taken. I also ride and camp in the George Washington National Forest. The economic case offered for rescission does not hold up against the agency's own figures. The record 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." The agency's 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 agency must explain on the record how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. Finally, the agency cites permitting and administrative burden as grounds for rescission. The rule as written already accommodates the situations most often 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)." The agency has not identified which specific burdens fall outside those existing exceptions. It should do so, in specific and quantified terms, before proceeding further. I often bird watch for pileated woodpeckers and Steller's jays. I fish for trout, bass, salmon and catfish. I ride my bike in the George Washington national forest. This rule is not abstract to me, and the agency's own numbers do not support removing it. Sincerely, Dean Harrisonburg, VA