Comment Analysis · Docket FS-2025-0001

FS-2025-0001-225007

Opposes rescissionA0 noneSubstance 4/24Posted 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

  • Water Quality Quantity
    • “Protection of Great Lakes Watersheds and Cold-Water Fisheries”
    • “Road construction in these light-soil ecosystems dramatically increases sediment runoff”
    • “Preserving intact roadless areas is critical to filtering drinking water and safeguarding Great Lakes water quality”
  • Recreation Tourism Public Use
    • “Preservation of Michigan's High-Value Backcountry Recreation”
    • “rare, semi-primitive motorized and non-motorized backcountry experiences”
    • “Michigan's outdoor recreation economy generates billions in GDP and supports tens of thousands of local jobs”
  • Economic Impact Fiscal
    • “Unmanageable Infrastructure Backlog”
    • “creates ongoing, unfunded maintenance commitments that local forest districts cannot sustain”
    • “increasing long-term taxpayer liabilities”
  • Forest Management Wildfire
    • “Fire Management Capabilities Already Exist”
    • “The current rule explicitly allows for active management, timber thinning, and fuel reduction”
    • “Stripping away nationwide protections to construct permanent roads deep into unroaded terrain is an unnecessary measure”

What it names

National Forests
Hiawatha National Forest

The comment

To Whom It May Concern: I am writing to express my strong opposition to the U.S. Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule. As a Michigan resident who relies on public lands for wilderness recreation, clean water, and regional economic stability, I urge the agency to maintain nationwide roadless protections for the Huron-Manistee National Forests in the Lower Peninsula and the Hiawatha National Forest in the Upper Peninsula. Decentralizing roadless protections and shifting to forest-by-forest management decisions will directly harm Michigan’s freshwater resources and outdoor heritage for the following reasons: 1. Protection of Great Lakes Watersheds and Cold-Water Fisheries: In Michigan’s Lower Peninsula, the Huron-Manistee National Forests encompass sensitive, sandy-soiled watersheds that feed world-class cold-water trout streams like the Au Sable, Manistee, and Pere Marquette rivers. Road construction in these light-soil ecosystems dramatically increases sediment runoff, exacerbates riverbank erosion, and destroys critical fish habitat. In the Upper Peninsula, the Hiawatha National Forest spans delicate wetland networks, peatlands, and riparian corridors connecting directly to Lake Michigan, Lake Superior, and Lake Huron. Preserving intact roadless areas is critical to filtering drinking water and safeguarding Great Lakes water quality. 2. Preservation of Michigan’s High-Value Backcountry Recreation: The Hiawatha National Forest offers rare, semi-primitive motorized and non-motorized backcountry experiences that draw hunters, anglers, campers, and hikers from across the Midwest. Rescinding the 2001 Rule threatens the remote, undisturbed character of these tracts. Michigan’s outdoor recreation economy generates billions in GDP and supports tens of thousands of local jobs; replacing a predictable national protection standard with localized management plans creates long-term uncertainty for the small business communities reliant on wilderness tourism across the U.P. and Northern Lower Michigan. 3. Unmanageable Infrastructure Backlog: The Forest Service already struggles with a massive deferred maintenance backlog across its existing forest road network. Adding new roads into unroaded areas of the Huron-Manistee and Hiawatha creates ongoing, unfunded maintenance commitments that local forest districts cannot sustain, increasing long-term taxpayer liabilities while existing forest roads remain under-maintained. 4. Fire Management Capabilities Already Exist: The argument that the 2001 Roadless Rule hinders forest health management is unsupported. The current rule explicitly allows for active management, timber thinning, and fuel reduction to combat insect infestations, disease, and fire risk when necessary. Stripping away nationwide protections to construct permanent roads deep into unroaded terrain is an unnecessary measure that compromises ecology without improving forest resilience. For these reasons, I urge the Department of Agriculture to withdraw this proposal and preserve the 2001 Roadless Area Conservation Rule in full. Sincerely, John Green Metro Detroit, MI

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