Comment Analysis · Docket FS-2025-0001

FS-2025-0001-605501

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS and Cost Benefit Analysis contain internal contradictions regarding wildlife impacts, water quality risks, economic net benefits, and wildfire safety that the agency has failed to reconcile in its proposal to rescind the 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 Analytical gap, 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

Wildlife Habitat
- “bird richness declines with road presence”
- “roads built for resource extraction may have altered mule deer migration routes”
- “Every road opened into these areas narrows the habitat birds and deer depend on”
Water Quality Quantity
- “Nothing is more important than clean drinking water”
- “378 municipal water intakes sit in watersheds containing affected roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
Recreation Tourism Public Use
- “The forest is peaceful because there aren't many roads there”
- “I hike and camp there, and fall is my favorite season”
- “recreation losses of at least $6.1 million a year”
Legal Regulatory Framework
- “The Tenth Circuit held... we REVERSE the district court's order”
- “found the rule within the authority Congress granted under the Organic Act and MUSYA”
- “The agency has not explained what legal basis exists for a contrary position”

What it names

National Forests: George Washington National Forest
Roadless areas: Gum RunOak KnobSouthern Massanutten
Law cited: 28 U.S.C. Section 1291

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The George Washington National Forest is where I go to recharge. I hike and camp there, and fall is my favorite season because of the mild temperatures and the colorful leaves. The forest is peaceful because there aren't many roads there. Southern Massanutten, where I live, is part of that beauty. Adding roads would drastically change this environment. I am asking you to keep the Roadless Rule fully intact. I love watching and listening to birds in the forest. Their calls are calming, and research has shown that listening to birds can reduce stress levels, positively impact mood, and improve cognitive function. The agency's own environmental analysis confirms what I experience: the DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. I also watch deer in these woods. The DEIS itself cites research finding that roads built for resource extraction may have altered mule deer migration routes and increased their movement speed, with the agency's own analysis identifying disrupted migration and lost unroaded security as the danger. Virginia holds 64 inventoried roadless areas totaling 393,682 acres, including Southern Massanutten, Gum Run, Oak Knob, Dry River, and Skidmore in the George Washington. Every road opened into these areas narrows the habitat birds and deer depend on. I ask the agency to explain, with specificity, how this rescission is compatible with what its own DEIS documents about roads and wildlife. Nothing is more important than clean drinking water. Rescinding the Roadless Rule would negatively impact the safety and availability of drinking water, and that is unacceptable. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of those watersheds have impaired streams today. Opening these roadless areas risks the majority that are still clean. The agency must explain what it intends to do to protect those watersheds if the rule that protects them is gone. If a road went into Southern Massanutten, I would be devastated. It doesn't make sense to create new roads when current roads aren't able to be maintained well. The agency is already carrying a $6.9 billion maintenance backlog on a road budget of roughly $73 million a year. The agency's own 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 must reconcile the proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain on the record how an action whose own numbers cannot establish a net benefit justifies expanding a road system already collapsing under its maintenance burden. The proposal also rests on a wildfire justification that the agency's own data contradicts. 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." The agency must reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why the proposal departs from this finding. Finally, the claim that the 2001 rule exceeded statutory authority is contradicted by the courts that reviewed it. The Tenth Circuit held, exercising jurisdiction under 28 U.S.C. Section 1291: "we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the rule within the authority Congress granted under the Organic Act and MUSYA, and found it did not create de facto wilderness. The agency has not explained what legal basis exists for a contrary position, and it should. Public land must be protected from development. The forest is peaceful because there aren't many roads there. Please don't change this. Sincerely, Katie in Massanutten, VA