Comment Analysis · Docket FS-2025-0001

FS-2025-0001-613031

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's cost-benefit analysis and regulatory flexibility analysis, citing a $6.9 billion maintenance backlog, a net present value range of -$92 to $199 million, and a contradiction between the small-business certification and the DEIS's identification of affected outfitters and guides, while requesting that the agency place the Cost Benefit Analysis on the docket, restate the net present value with included road and fuel costs, and analyze an alternative retaining the 2001 rule's protections.

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
- “Road appropriations fell from $234 million in 2004 to $73 million in 2024”
- “deferred maintenance backlog of $6.9 billion for roads and bridges”
- “net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million”
- “I care how my tax money gets spent”
Governance Policy Process
- “The analysis was published in an agency file folder rather than on the docket”
- “I ask that the agency place the Cost Benefit Analysis on the docket”
- “I ask that the agency acknowledge the change in position and provide a reasoned explanation”
- “The small-business certification contradicts the analysis beside it”
Recreation Tourism Public Use
- “DEIS names outfitters, guides and tour operators as affected”
- “books lost recreation benefit at a minimum of $6.1 million a year”
- “assess the impact on the small entities actually operating in the potentially affected roadless areas”
Tribal Sovereignty
- “the land should be managed by the native peoples”
- “who have already been scammed out of it 3 times”

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 gapEvidenceRequestLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The wanton destruction and the capitalistic orgy of excess is a waste of every dime. I am already pretty sure my youngest children will be among the first to starve because of the already unchecked shit you people do. Seriously, the land should be managed by the native peoples who have already been scammed out of it 3 times. There is no excuse for this. There is no reason. Release the Epstein files, execute the wannabe dictator and for the love of all that is decent just stop breaking shit like angry toddlers. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The agency cannot afford the roads it already has This is my money. Before the agency commits to building more, I want it to account for what it already cannot maintain. 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. The DEIS states that road mileage, deferred maintenance and management costs are likely to increase under the proposal. I ask that the agency name the funding source for new road construction and maintenance and state the projected change in the backlog. Issue 2: The agency's own accounting cannot say if this makes money or loses it I care how my tax money gets spent, and I expect an honest accounting before public assets are traded away. The agency's own analysis cannot provide one. The Cost Benefit Analysis: "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." The cost column excludes the road construction ($80,000 to $100,000 per mile, roughly $500,000 per mile in Alaska), maintenance and fuel treatment costs the same document quantifies, and the upper bound assumes maximum potential harvest the analysis itself calls uncertain. An economically significant rule whose own analysis spans from a $92 million loss to a $199 million gain has not shown a benefit; the analysis was published in an agency file folder rather than on the docket, and the rule's claim that impacts "could exceed $100 million" (91 FR 53830) appears with no arithmetic anywhere, though every quantified annual line item is under $22 million. I ask that the agency place the Cost Benefit Analysis 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 the statement that impacts could exceed $100 million. Issue 3: The small-business certification contradicts the analysis beside it I care where the costs of this decision land, because it is my money either way. The certification here does not survive the analysis printed 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. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Michael Mastropietro Girard, Ohio