Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606078

Opposes rescissionA2 moderateSubstance 17/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's justification for rescinding the Roadless Rule is unsupported by ignition data and existing access statistics, and requests specific documentation of denied treatments, fire outcome data for Alternative 3 acres, and evidence of tribal consultation.

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, Evidence.

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

Recreation Tourism Public Use
- “hiking in the White Mountain National Forest for close to 30 years”
- “places worth going back to are the ones that haven't been cut up by new roads”
- “big, quiet, and unfragmented”
- “17,700 miles of hiking and biking trails”
Forest Management Wildfire
- “wildfire rationale has to be tested against ignition data”
- “only 3% of mapped ignition points over 50 years fall inside inventoried roadless areas”
- “roadless areas have not burned at significantly higher rates or severity than roaded forest”
- “rule permits fire suppression, tree cutting to reduce wildfire risk”
Legal Regulatory Framework
- “FLPMA section 103(c) defines multiple use”
- “The 2001 rule already allows the work the agency says it needs”
- “FLPMA section 205 gives the Secretary of Agriculture authority to acquire access”
- “Congress did give the Secretary of Agriculture rulemaking authority”
Tribal Sovereignty
- “FLPMA section 202(b) directs the Secretary of Agriculture to coordinate National Forest land use plans with tribal land management programs”
- “document government-to-government consultation with each tribe”
- “tribes that have treaty or ancestral ties to affected forests”

What it names

National Forests: White Mountain National Forest
Roadless areas: Indian CreekWhite Mountain

The comment

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

I support Alternative 1 (No Action) and oppose Alternatives 2 and 3. I've been hiking in the White Mountain National Forest for close to 30 years, including the Baldface Loop and the Presidential Range, and I climb and explore public land across the country. That includes the Isabelle Glacier Trail in Colorado, one of the last glaciers you can still hike to, and the crags of Beef Basin near Indian Creek in Utah. What keeps me coming back to all of these places is that they are still big, quiet, and unfragmented, and the Roadless Rule is one of the few tools that keeps National Forest land that way. After three decades in the Whites, I can say from experience that the places worth going back to are the ones that haven't been cut up by new roads. 1. The wildfire rationale has to be tested against ignition data. USDA points to about 28 million roadless acres at high or very high fire risk, and to roughly 80 million acres of National Forest land that need fuel or forest health treatment. Those problems are real. The question for this rulemaking is whether rescission addresses them. onX's analysis of National Interagency Fire Center records found that only 3% of mapped ignition points over 50 years fall inside inventoried roadless areas. Published research puts about 90% of wildfires within a half mile of a road, and 88% of wildfires are human caused. A four-decade satellite analysis found roadless areas have not burned at significantly higher rates or severity than roaded forest, and burned slightly less in the most recent decade. The Final EIS should state how many miles of new road the preferred alternative projects, what change in human-caused ignitions that mileage would produce using the agency's own fire records, and how much of the 28 million acres is already close enough to an existing road to be treated today. 2. The 2001 rule already allows the work the agency says it needs. The rule permits fire suppression, tree cutting to reduce wildfire risk, fuel treatments, and road construction when a threat is imminent. I ask the agency to list every treatment proposal in an inventoried roadless area since 2001 that was denied or delayed because of the rule, with the reason for each. If the list is short, the DEIS has not shown a problem that rescission solves. 3. Multiple use is already met across the National Forest System. FLPMA section 103(c) defines multiple use to include "the use of some land for less than all of the resources," and says management should not automatically pursue the mix that returns the most money. Section 102(a)(8) calls for preserving certain lands in their natural condition while still providing for recreation and human use. I recognize FLPMA's planning title is written mainly for BLM lands. Congress did give the Secretary of Agriculture rulemaking authority for National Forest System lands in section 310, and the 103(c) definition closely tracks the Multiple-Use Sustained-Yield Act the Forest Service already works under. onX's figures show roadless areas are 27.7% of the 193 million acres the agency manages, while 51.7% is managed for other values and a broader range of uses. The Final EIS should explain how that existing mix fails the multiple use standard. 4. The rule does not close existing access. onX counted 7,201 miles of full-size motorized trails and primitive roads, 2,494 miles of ATV and side-by-side trails, 2,167 miles of motorized singletrack, and 1,295 miles of snowmobile trails inside these areas, along with over 17,700 miles of hiking and biking trails, nearly 1,500 miles of mapped ski routes, and close to 3,000 climbing areas. The rule bars construction and reconstruction of roads. It does not shut those routes. Where public access gets lost is at the boundary. FLPMA section 205 gives the Secretary of Agriculture authority to acquire access over non-federal lands to National Forest units, which is the tool for landlocked parcels. I ask the agency to quantify roadless acres that lack legal public access, and to compare the cost of new road construction in roadless areas with the cost of acquiring access easements. 5. Alternative 3 removes protection where ignition risk concentrates. Alternative 3 strips designation from 31.7 million acres, including everything within a half mile of a road. That is the same band where the ignition research says most fires start. It also removes the 9.3 million acres of the Tongass. Please provide fire outcome data for the specific acres Alternative 3 would remove. 6. Tribal coordination and process. FLPMA section 202(b) directs the Secretary of Agriculture to coordinate National Forest land use plans with tribal land management programs and to consider approved tribal land resource management programs. I ask the agency to document government-to-government consultation with each tribe that has treaty or ancestral ties to affected forests, and to show how their programs were weighed. Thank you, Amy Broman Massachusetts