Comment Analysis · Docket FS-2025-0001

FS-2025-0001-612820

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment places on the record specific deficiencies in the agency's analysis regarding wildfire ignition data, economic cost-benefit projections, and water quality impacts, while citing specific locations in Shawnee National Forest and legal precedents from the Tenth Circuit and Federal Register to challenge the statutory authority and consistency of the proposed rescission.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Recreation Tourism Public Use
- “The outdoors is my cathedral, and time spent there is sacred”
- “More roads would severely detract from those spaces that still feel wild”
- “My children need this land to unplug and maintain their sanity”
- “recreation losses of at least $6.1 million a year”
Water Quality Quantity
- “286 municipal water intakes sit in watersheds containing affected roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “fewer than 12 percent of those watersheds have impaired streams today”
- “pissing in your Cheerios”
Forest Management Wildfire
- “A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the rescission with the ignition data in its own draft environmental impact statement”
- “far higher fire density on roaded land than inside the affected roadless areas”
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
Legal Regulatory Framework
- “The Tenth Circuit held that the 2001 rule fell within the authority Congress granted”
- “The Ninth Circuit already reviewed a state-by-state replacement and found it wanting”
- “The agency must state, with legal grounding, the basis for any position contrary to that holding”
- “Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order”

What it names

National Forests: Mark Twain National Forest Shawnee National Forest
Roadless areas: Burden FallsClear SpringsRipple Hollow
Law cited: 28 U.S.C. Section 1291

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The outdoors is my cathedral, and time spent there is sacred. Places like Bell-Smith Springs and the Lusk Wilderness areas in Shawnee National Forest are not always free of other visitors, but a trip there is restorative nonetheless. I also visit Mark Twain National Forest when I can. The areas I am most concerned with are inventoried roadless units in Shawnee: Burden Falls, Clear Springs, and Ripple Hollow. Illinois holds 6 inventoried roadless areas totaling 10,673 acres. That is not much. More roads would severely detract from those spaces that still feel wild, and it would be a shame to create more inroads into them and ruin the solace they provide. I am also an amateur birder whose senses still awaken with the spotting of a Cardinal or some woodpecker. And I roadtrip to the western United States nearly annually to photograph landscapes I do not see in the Midwest, places like the Badlands, Capitol Reef, Bryce Canyon, and Zion. The joy is in the discovery. Public land needs to be managed in the interest of my grandchildren's grandchildren. My children need this land to unplug and maintain their sanity as much as I do. On the wildfire justification: the proposal points to fuels management as a reason to rescind the rule and open roadless areas to new construction. The agency's own record states that "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." That finding belongs to the agency, not to its critics. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence, and reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. On economics: the agency's own record states that "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." There is no fiscal sense in spending money on new roads before fixing those already in existence, and any new road construction should carry public budgetary oversight. The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. How does an action whose own analysis cannot establish a net benefit justify expanding a road system already carrying a $6.9 billion maintenance backlog? On water: across the Eastern region, which includes Illinois, 286 municipal water intakes sit in watersheds containing affected roadless areas. Building new roads in that context is, as my grandfather would have said, pissing in your Cheerios. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and fewer than 12 percent of those watersheds have impaired streams today. The agency should state plainly what it projects will happen to that figure under the rescission, and it should do so in the record. On the state-by-state approach: the proposal argues that local rules can replace a national one, but the agency's own prior record shows it acknowledged "its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit already reviewed a state-by-state replacement and found it wanting. On statutory authority: the proposal suggests the 2001 rule exceeded what Congress authorized. A federal appellate court resolved that question. Its holding reads: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit held that the 2001 rule fell within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must state, with legal grounding, the basis for any position contrary to that holding. Burden Falls is partly protected by the difficult road required to reach it. The falls themselves only flow during or after heavy rain. I have never seen them with water, but the area is still worth climbing through. That kind of place, earned by effort and left largely as it is, is worth keeping. A logged stand grows back. A road does not. Sincerely, [Your Name] [Your City, State]