Comment Analysis · Docket FS-2025-0001

FS-2025-0001-224013

Opposes rescissionA0 noneSubstance 6/24Posted August 20, 2026 On Regulations.gov

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

A0 none: Counted, not answered.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Forest Management Wildfire
- “USDA cites wildfire risk reduction as justification, but the evidence points the opposite way”
- “fire ignition density is highest near roads”
- “Building new roads into roadless areas would increase, not reduce, wildfire risk”
Water Quality Quantity
- “protect drinking-water source watersheds”
- “interconnected watersheds”
Wildlife Habitat
- “wildlife corridors”
- “protect... wildlife habitat”
Recreation Tourism Public Use
- “thousands of miles of trails that support hunting, fishing, and outdoor recreation economies”
- “spent time in the backcountry”

What it names

National Forests: Sawtooth National Forest

The comment

I oppose rescinding the 2001 Roadless Area Conservation Rule and urge USDA to withdraw this proposal. I've spent time in the backcountry of Idaho's Sawtooth National Forest. Sawtooth itself falls under the separate 2008 Idaho Roadless Rule, but it sits amid the same interconnected watersheds, wildlife corridors, and recreation networks the 2001 Rule protects across neighboring states. Weakening the national standard sets a precedent that puts every regional variant, including Idaho's, at greater risk down the line. USDA cites wildfire risk reduction as justification, but the evidence points the opposite way. Roughly 85–89% of U.S. wildfires are human-caused, and multiple studies — including a 30-year Forest Service ignition dataset — show fire ignition density is highest near roads (up to 4x higher than in roadless areas) because roads bring people, the dominant ignition source, deeper into the backcountry. Building new roads into roadless areas would increase, not reduce, wildfire risk. Roadless areas also protect drinking-water source watersheds, wildlife habitat, and thousands of miles of trails that support hunting, fishing, and outdoor recreation economies across the West. I ask USDA to retain the 2001 Roadless Rule in full rather than eliminate baseline protections for the remaining 45 million acres it covers.