Comment Analysis · Docket FS-2025-0001

FS-2025-0001-609252

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding wildfire ignition data (DEIS Table 21), water quality sediment impacts, and economic cost-benefit calculations, while asserting the commenter's reliance interest in the existing protections of the Allegheny National Forest roadless areas.

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

Environmental Protection Biodiversity
- “abundant wildlife”
- “only 1% of old growth forest left”
- “Wildlife depends on these areas for survival”
- “once that ground is opened to roads... it does not come back”
Water Quality Quantity
- “feed 7,000 municipal water intakes”
- “24 million Americans drink water that starts there”
- “roads and their facilities can produce up to 90% of the sediment”
- “Do not disturb this natural balance”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the rescission with its own ignition data”
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent”
- “road system already carrying a $6.9 billion maintenance backlog”
- “recreation losses of at least $6.1 million a year”
- “net present value spanning a range the analysis itself cannot resolve in favor of the action”

What it names

National Forests: Allegheny National Forest
Roadless areas: Allegheny FrontClarion RiverHearts ContentMinister Valley

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 trail at Jake's Rocks runs through a forest that still holds some of the rarest ground in the eastern United States. I bike there because the Allegheny National Forest is a beautiful natural area with abundant wildlife, and it should stay that way. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens that, and I oppose it. Pennsylvania holds 7 inventoried roadless areas totaling 24,866 acres. The areas I know and care about, including Clarion River, Minister Valley, Hearts Content, and Allegheny Front, are part of that inventory. There is only 1% of old growth forest left in the eastern United States. Wildlife depends on these areas for survival, and once that ground is opened to roads and the disturbance that follows, it does not come back. I ask the agency to explain in its final record what it finds insufficient about the protections these specific areas currently receive. The agency's own prior findings on wildfire should stop this proposal in its tracks. The 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." If the agency now proposes to open roadless areas in the name of fuels management, it must explain why it is departing from that conclusion, and it must reconcile the rescission with its own ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The current roads in the Allegheny are not properly maintained. It makes no sense to build more roads through this area when the existing ones are neglected. The agency's own record makes the same point in economic terms: "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." A road system already carrying a $6.9 billion maintenance backlog on a budget of roughly $73 million a year cannot absorb new miles in exchange for returns that small. I ask the agency to reconcile the proposal with its own Cost Benefit Analysis, which projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value spanning a range the analysis itself cannot resolve in favor of the action. These roadless areas feed 7,000 municipal water intakes, and the agency's own data report that about 24 million Americans drink water that starts there. Across the Eastern region, which includes Pennsylvania, 286 municipal water intakes sit in watersheds containing affected roadless areas. Fewer than 12% of those watersheds have impaired streams today, and the agency's own analysis finds that roads and their facilities can produce up to 90% of the sediment from a timber sale. Do not disturb this natural balance. The agency must address what opening these watersheds to road construction does to that sediment load and to the communities downstream who depend on water that begins in places like Clarion River and Minister Valley. The regulatory flexibility analysis accompanying this proposal certifies no significant impact on small entities, yet "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 losses across every small firm in the sector nationally, not by assessing the guides and outfitters who actually hold permits in the affected areas. The agency should withdraw the certification and assess the impact on the businesses operating in the roadless areas themselves. 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. I have planned my recreation, my sense of what this forest is, and my expectations of its future around protections that have been in place for more than two decades. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it takes any further action. Sincerely, Paula Adams Pittsburgh, PA