Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606071

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS and Cost Benefit Analysis contain specific data on bird abundance, water sediment, wildfire ignition densities, and small entity losses that are not reconciled with the proposal's conclusions, and requests that the agency quantify these impacts and weigh the stated reliance interests.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap.

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.
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.

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.
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

Wildlife Habitat
- “Much wildlife, including migrating birds, like warblers and vireos, draw me to these forests”
- “bird richness declines with road presence in forested habitat”
- “road-noise experiments in a roadless area cut bird abundance by over a quarter”
Water Quality Quantity
- “Clean drinking water is imperative”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “more than 7,000 municipal water intakes sit in watersheds fed by roadless areas”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
Recreation Tourism Public Use
- “The George Washington National Forest offers some respite from the busy and fragmented Eastern United States”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “Places to recreate, undisturbed space for wildlife and birds”

What it names

National Forests: George Washington National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The George Washington National Forest offers some respite from the busy and fragmented Eastern United States, and that respite depends on what the Roadless Area Conservation Rule has protected. I oppose rescission of that rule and ask the agency to address the following. Much wildlife, including migrating birds, like warblers and vireos, draw me to these forests, and the agency's own research documents what roads do to them. 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. If the agency proceeds, it should explain what weight it gave these documented effects on bird communities in areas like the George Washington when it concluded that rescission would not cause significant harm. Clean drinking water is imperative. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and the record reflects that more than 7,000 municipal water intakes sit in watersheds fed by roadless areas, with approximately 24 million Americans drinking water that originates there. Fewer than 12 percent of those watersheds have impaired streams today. Opening roadless lands to road construction risks that record. The agency should explain what analysis on water quality it conducted before concluding that ending the roadless rule is in the public interest. On wildfire, the agency's own record 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 proposal nonetheless justifies rescission partly on fuels and wildfire management grounds. The DEIS reports human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that "human-caused ignitions increase in abundance with proximity to roads." These figures are not reconciled with the claimed wildfire rationale. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard, and separately explain why the proposal departs from its own prior findings as documented in DEIS Table 21. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading loss across every small firm in the sector nationally rather than examining the outfitters and guides actually holding permits in the affected areas. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. Places to recreate, undisturbed space for wildlife and birds, and clean water sources have been protected party due to this rule. Under the legal standard governing agency reversals, those interests must be identified and weighed, not solicited and then omitted from analysis. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Amy Risko Harrisonburg, VA 22801