Comment Analysis · Docket FS-2025-0001

FS-2025-0001-613098

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's draft EIS and cost-benefit analysis contain internal contradictions regarding wildfire ignition rates on roaded versus unroaded lands and net economic benefits, and requests that the agency reconcile these findings with DEIS Table 21 and identify specific operational burdens not covered by existing regulatory exceptions before proceeding with the 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, Evidence, 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

Forest Management Wildfire
- “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 DEIS Table 21”
- “far higher fire density on roaded land than inside the affected roadless areas”
Water Quality Quantity
- “286 municipal water intakes sit in watersheds containing affected roadless areas”
- “local decision-making can incrementally erode nationally significant roadless values”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year”
- “agency is also already $6.9 billion behind on maintaining the roads it has”
Environmental Protection Biodiversity
- “Photographing the biodiversity in places like these”
- “places I visit and care about passing to the next generation”
- “natural heritage”

What it names

Roadless areas: Rocky Mountain
Law cited: 36 C.F.R. Section 294.12

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 Rocky Mountain National Park is one of my holy places, and I am in Michigan's public lands almost weekly. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The agency has framed this proposal partly as a wildfire management measure. Its own record says otherwise. The agency's own draft environmental impact statement 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." Michigan holds 6 inventoried roadless areas totaling 16,124 acres. Photographing the biodiversity in places like these, in national forests and parks, is something I do almost every week. These are not abstractions to me. They are places I visit and care about passing to the next generation. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not support this action either. 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." To take and extract without studying the impacts is myopic and serves only greed and one sector of our country. That is not managing for what is best for all Americans and the long view. The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency is also already $6.9 billion behind on maintaining the roads it has, against a road budget of about $73 million a year. Roads in natural areas are disruptive and rude. Once made, you cannot go back. How does the agency justify expanding a road system already carrying a $6.9 billion maintenance backlog when its own analysis cannot establish a net benefit from this rescission? The proposal suggests that state-specific approaches can replace a national rule. The record shows the agency has tried this before. The agency's own record acknowledges that "the USDA discussed 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 Roadless Rule was a very long and well thought out process. Replacing it with state-by-state management did not survive judicial review the last time it was attempted. Across the Eastern region, which includes Michigan, 286 municipal water intakes sit in watersheds containing affected roadless areas. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified when the agency last took this path. Finally, much of what the agency says the rule prevents, the rule already permits. The rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." This latest move reads as the burp of destruction from those who do not have our natural heritage in mind, not a careful administrative correction. The agency has not identified, with specificity and with numbers, which operational burdens are not already addressed by these existing exceptions. It should do exactly that before proceeding further. These public lands are the best of the best. Just knowing wild places still exist is a thrill and spirit-lifting. The agency must justify this rescission through its own evidence, not in spite of it. Sincerely, M Lorenz Kewadin, MI