Comment Analysis · Docket FS-2025-0001

FS-2025-0001-608207

Opposes rescissionA2 moderateSubstance 9/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's Cost Benefit Analysis and small-business certification are deficient because they exclude quantified road construction costs, rely on an uncertain net present value range, and fail to assess specific local entities, while also noting that the CBA was not placed on the docket.

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

Economic Impact Fiscal
- “The agency cannot afford the roads it already has”
- “deferred maintenance backlog of $6.9 billion”
- “net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million”
- “The financial case for rescission has not been made”
Recreation Tourism Public Use
- “where I go to get exercise and to disconnect from the normal daily routine”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “recreation and tourism businesses tied to clean water and intact landscapes”
- “outfitters, guides and tour operators as affected”
Governance Policy Process
- “The 2001 rule was written after more than 600 public meetings and 1.6 million public comments”
- “This rescission has been pursued without any equivalent process”
- “The agency is obligated to identify and weigh the reliance interests”
- “The Cost Benefit Analysis was placed in an agency file folder, not on the docket”
Water Quality Quantity
- “378 municipal water intakes draw from watersheds containing roadless areas”
- “recreation and tourism businesses tied to clean water”
- “intact landscapes are concentrated exactly where the impacts would fall”

What it names

Works cited: Furniss et al. 1991

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 The mountains of North Carolina are where I go to get exercise and to disconnect from the normal daily routine. I cannot imagine this country without them. The roadless areas within those mountains, all 172,416 acres across 38 inventoried areas, are part of what makes that possible. This proposed rescission would place all of it at risk, and I oppose it without qualification. The agency cannot afford the roads it already has, and nothing in this record explains how it would pay for new ones. The DEIS acknowledges that road mileage, deferred maintenance and management costs are all likely to increase under the proposal. The agency's own figures make that problem concrete: "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." Opening North Carolina's roadless areas to new construction means adding to a backlog the agency has spent two decades failing to address. I want the agency to name, specifically and in writing, the funding source for any new road construction and maintenance in these areas, and to state the projected change in that backlog under the proposal. The financial case for rescission has not been made. The agency's Cost Benefit Analysis states that "the net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million (-$70 to $152 million discounted at 7 percent) and uses maximum potential costs and benefits that do not account for uncertainty." A range that spans from a $92 million loss to a $199 million gain is not a demonstration of benefit. It is an admission that the agency does not know. That range becomes still less credible when the cost column excludes the road construction costs of $80,000 to $100,000 per mile that the same document quantifies. The Cost Benefit Analysis was placed in an agency file folder, not on the docket. I ask that the agency place it on the docket, restate the net present value with its own quantified road and fuels costs included in the cost column, and show the arithmetic behind any claim that impacts could exceed $100 million. The small-business certification in this rulemaking contradicts the analysis sitting beside it. "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 was reached by spreading losses across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. North Carolina alone sits within a Southern region where 378 municipal water intakes draw from watersheds containing roadless areas, which means recreation and tourism businesses tied to clean water and intact landscapes are concentrated exactly where the impacts would fall. The agency must withdraw that certification and assess the entities actually operating in these places. National forests are one of this country's, and the world's, few remaining national treasures. That is not sentiment; it is a statement about scarcity. The 2001 rule was written after more than 600 public meetings and 1.6 million public comments. This rescission has been pursued without any equivalent process. Disrupting the natural state of these places with roads and logging is the opposite of what the agency should be doing, and this comment represents precisely the kind of reliance interest the agency itself acknowledged when it solicited "any reliance interests in the current rule that could be affected by this proposal." The Cost Benefit Analysis weighs none of them. The agency is obligated to identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Ian H. Charlotte, NC