Comment Analysis · Docket FS-2025-0001

FS-2025-0001-224123

Opposes rescissionA1 strongSubstance 3/24Owed an answerPosted 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

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

Owed an answer on 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.
  • 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.
  • 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.
  • 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.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

Topics

  • Forest Management Wildfire
    • “Intact forests that have not been logged have uneven-aged stands... not as prone to dangerous crown fires”
    • “Roads bring people, vehicles and activity, which bring sources of ignition”
    • “what usually happens is that areas are clearcut, leaving even-aged stands to grow up and be more fire-prone”
  • Environmental Protection Biodiversity
    • “it produces services of great value: clean water, clean air, fish and wildlife, natural beauty, soil formation, erosion prevention”
    • “fire-adapted ecosystems that naturally burn and re-grow”
    • “Just leave them alone”
  • Resource Development Extraction
    • “it's obvious that exploitation is the goal”
    • “Once there are mines, oil wells and lumber camps, there will be more infrastructure and people to protect”
    • “Timber production is not the same as 'targeted fuels treatments'”
  • Governance Policy Process
    • “The best way to promote predictability is not to change the rule”
    • “Uncertainty will be magnified when each forest service unit creates its own plans”
    • “heavy-handed Federal policies have prevented full utilization of these resources”

What it names

Law cited
E.O.12866EO. 13563

The comment

I am opposed to rescinding the roadless rule for the following reasons. Fire danger: Intact forests that have not been logged have uneven-aged stands, larger trees farther apart, and more moisture-absorbing ground cover. They are not as prone to dangerous crown fires as logged areas that have grown up as even-aged stands and are choked with small trees and brush. Roads bring people, vehicles and activity, which bring sources of ignition. When you talk about forest management for fire prevention, you may be hoping that we imagine brush clearing or managed burns. But in fact, what usually happens is that areas are clearcut, leaving even-aged stands to grow up and be more fire-prone. You quote President Trump as saying, “the United States has an abundance of timber resources that are more than adequate to meet our domestic timber production needs, but heavy-handed Federal policies have prevented full utilization of these resources.” Timber production is not the same as “targeted fuels treatments.” In fact, it can be the opposite. Many areas, especially in the west, have fire-adapted ecosystems that naturally burn and re-grow when ignited by lightning, for example. In a roadless area that is far from human settlement, fires can be allowed to take their course. Once there are mines, oil wells and lumber camps, there will be more infrastructure and people to protect and a greater need for fire suppression. Ecosystem Services: To some people, an intact forest produces nothing unless it is logged or mined. But in fact, it produces services of great value: clean water, clean air, fish and wildlife, natural beauty, soil formation, erosion prevention. Development: Even though you say that rescinding the rule only provides flexibility and doesn’t actually require road building, logging or mining, it’s obvious that exploitation is the goal. You mention the income that could be produced for timber companies and the federal government if logging is allowed. But it’s well known that the government subsidizes logging on federal land, so it would be a money loser for the taxpayer. Predictability: “EO. 13563 reaffirms the principles of E.O.12866 while calling for improvements in the Nation’s regulatory system to promote predictability, to reduce uncertainty, and to use the best, most innovative, and least burdensome tools for achieving regulatory ends.“ The best way to promote predictability is not to change the rule! Uncertainty will be magnified when each forest service unit creates its own plans. I feel like I’ve spent my whole adult life trying to keep roadless areas from being opened up. When is this going to stop? Just leave them alone.

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