Comment Analysis · Docket FS-2025-0001

FS-2025-0001-607431

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the Roadless Rule protects critical water sources, wildlife habitat, and economic assets in Virginia, specifically citing data on filtration cost savings in Harrisonburg, tourism revenue in the George Washington National Forest, and fire management efficiency, to support retaining the rule under Alternative 1.

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 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

Water Quality Quantity
- “clean drinking water”
- “rivers and streams in Virginia's roadless feed into reservoirs and aquifers”
- “saves multiple millions of dollars in filtration costs”
- “access to clean water will be threatened”
Wildlife Habitat
- “home to hundreds of species that depend on unbroken forest habitat”
- “Whitetail deer and bear... require large unbroken tracts of habitat”
- “brook trout... depend on extremely specific water conditions”
- “roads are key to the spread of invasive plant species”
Recreation Tourism Public Use
- “incentive for hunting, wildlife photography, and other types of recreation”
- “massive tourism draw”
- “generate around $300 on average for local tourism-related business”
- “sharp decrease in tourist and local dollars”
Forest Management Wildfire
- “no evidence that fire management is hampered by roadless areas”
- “fire risks are approximately equal inside and outside of roadless areas”
- “Roadless areas, then, naturally leave forests more resilient to fire”
- “USFS can ill afford to create new roads”

What it names

National Forests: George Washington National Forest

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

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

For the last 25 years, the Roadless Rule has been key to protecting nearly 400,000 acres of land and 545 miles of river in my home state of Virginia. These forests and waters are home to hundreds of species that depend on unbroken forest habitat & clean, unpolluted rivers to survive. In addition to animal life, hundreds of thousands of people depend on these roadless areas for clean drinking water, as rivers and streams in Virginia’s roadless feed into reservoirs and aquifers supplying water to cities and rural communities. As a refuge for wildlife, roadless areas are critically important. Whitetail deer and bear are two major inhabitants of the state’s national forests, and require large unbroken tracts of habitat to flourish. These species are an incentive for hunting, wildlife photography, and other types of recreation that attracts people to these areas. Others, such as brook trout - another recreation-linked species - depend on extremely specific water conditions to thrive; road construction and logging runoff would decimate their populations in Virginia’s forests and drive away significant tourist dollars in lost fishing revenue; similarly, lack of roadless area for hunting access will decrease use from hunters and those who depend upon wild game for food. Readily available clean drinking water is critical to every community in the state, and for many places, the clean water flowing from streams saves countless dollars that would otherwise be spent on filtration. It is estimated that Harrisonburg alone saves multiple millions of dollars in filtration costs by virtue of water sources in the George Washington National Forest - costs that would otherwise be passed on to taxpayers to ensure a similar standard of hygiene (Hilt, 2026). Roadless areas, with their lack of pollution and intact vegetative communities - which help to filter rainwater as it flows into streams and aquifers - are hereby a critical contributor to the infrastructure of communities across the state whose access to clean water will be threatened. Should this rule be repealed, over 3 million people who depend on roadless areas in national forests in Virginia will have their access to clean water diminished (Hilt, 2026). Roadless areas are also a massive tourism draw. The George Washington National Forest is scarcely two hours from some 10 million potential visitors; Virginia’s national forests (including the GWNF) see some 3.8 million visitors per year. Of these 3.8 million, 80% are non-local; each of these national forest visits in the state generate around $300 on average for local tourism-related business - $1.4 billion in total per year (Friends of Shenandoah Mountain, n.d). Lack of access to these areas would undoubtedly cause a sharp decrease in tourist and local dollars flowing into the local economy. Perhaps most importantly - and despite protestations to the contrary by USDA officials who are discounting the scientific expertise present in the agency - there is no evidence that fire management is hampered by roadless areas; rather, “fuel management activities in roadless areas have actually been more numerous on a per-square kilometer basis than elsewhere in the National Forest System” (Healy, 2020, p.1). According to recent research, “fire risks are approximately equal inside and outside of roadless areas. Further, inventory data suggest that roads are key to the spread of invasive plant species, a long-term threat to the function and composition of federal forests,” (Healy, 2020, p. 4). Roadless areas, then, naturally leave forests more resilient to fire and the threat of invasive species. Additionally, the USFS can ill afford to create new roads - most of which will not be open to the public - while it still carries an infrastructure maintenance backlog of over $5 billion for roads and other infrastructure (Blue Ribbon Coalition, 2025; USFS, n.d.). Additionally, logging has historically been a much less efficient use of taxpayer money than leaving roadless lands alone & reaping economic benefits as a windfall of ecological process (see above regarding clean water, recreation, etc.). Timber sales are a net loss to taxpayers, with management for carbon sequestration and ecosystem benefits producing more than twice the value of timber sales (Talberth, 2019).. It is estimated that – while they take up only 1% of the country’s area – roadways affect around 20% of the land in the U.S. due to impacts that stretch beyond their edges (Clevenger & Huijser, 2011; Donaldson & Weber, 2006; Iuell, Bekker, Cuperus, et al., 2003; Wade et al., 2003). I support Alternative 1; keep the Roadless Rule and the tangible benefits it brings to Virginia’s communities. Repealing this rule will not make our local communities safer, more prosperous, or competitive, but it will irrevocably scar landscapes that provide far more tangible benefits than unsustainable logging and the profits it stands to raise for a small few.