Comment Analysis · Docket FS-2025-0001

FS-2025-0001-240712

Opposes rescissionA1 strongSubstance 7/24Owed an answerPosted August 21, 2026 On Regulations.gov

In short: The comment documents specific recreational use of roadless areas in five named National Forests and requests the withdrawal of the proposed rescission of 36 CFR Part 294, Subpart B, arguing that the 30-day comment period is insufficient for a rulemaking of this magnitude.

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.
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

Recreation Tourism Public Use
- “hunted and fished the roadless drainages”
- “quiet, the intact habitat, and the sense that you have walked far enough from the road to be somewhere genuinely wild”
- “backcountry experiences that draw millions of Americans into the woods every year”
- “shared inheritance is what makes this country great”
Wildlife Habitat
- “security cover for elk and deer”
- “intact fisheries”
- “last places where game can find refuge from pressure”
- “safeguards the core habitat our hunting and fishing traditions depend on”
Governance Policy Process
- “Reject eliminating the national roadless standard in favor of piecemeal, forest-plan-level decisions”
- “patchwork of local decisions provides no durable protection”
- “Extend the public comment period”
- “Thirty days is far too short for a rulemaking of this magnitude”
Water Quality Quantity
- “fished cold, clear streams you can only reach on foot”
- “clean water our fisheries need”
- “undisturbed, cold-water habitat”

What it names

National Forests: Siskiyou National Forests Tongass National Forest
Law cited: 36 CFR Part 294

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal

I am writing to strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. For more of my life than not, the roadless backcountry of the Pacific Northwest has been the ground where my most meaningful experiences have taken place. Over the last five years alone, my family and I have hunted and fished the roadless drainages of the Mount Hood, Umpqua, Malheur, Wallowa-Whitman, and Rogue-Siskiyou National Forests. I have hunted elk in the cool, still timber of Oregon's roadless drainages and fished cold, clear streams you can only reach on foot — in the steep, timbered draws of the Umatilla, the high breaks of the Malheur, the wild corner of the Wallowa-Whitman, and the old-growth salmon country of the Rogue-Siskiyou. The places where gates mark the beginning of an American adventure have impacted me, my family, and my community unlike any other. None of that exists without the quiet, the intact habitat, and the sense that you have walked far enough from the road to be somewhere genuinely wild. The Roadless Rule is the reason those places are still there. What this proposed rescission would do is invite new road building and timber harvest into the very places that make those experiences possible. The administration frames this as a move to "ramp up timber development and road building" on roadless lands. Roads beget more roads; once a roadless area is cut by a road, the solitude, the security cover for elk and deer, the intact fisheries, and the feeling of being somewhere apart never fully come back. You cannot un-ring that bell. For hunters and anglers, roadless areas are not abstract — they are the last places where game can find refuge from pressure and where fish can hold in undisturbed, cold-water habitat. I am also writing because I believe public lands and roadless areas are one of the most profoundly American things about this country. We are a nation that, almost alone among nations, decided that vast wild places should belong to everyone — not to kings, not to the wealthy, not to whoever could get there first and fence it off, but to the people. That idea is exceptional, and it is worth defending. A factory worker in Portland and a schoolteacher in Burns can each load up a truck and drive to the same elk camp, the same trout stream, the same ridge where you can see a hundred miles and hear nothing but the wind. That shared inheritance is what makes this country great. Rescinding the Roadless Rule chips away at that inheritance — it says the wild places that belong to all of us can be opened for the few who profit from their extraction. That is not the American promise. That is the opposite of it. For more than two decades the Roadless Rule has protected roughly 58.5 million acres of national forest backcountry. It is backed by hunters, anglers, outfitters, tribal nations, small businesses, and ordinary Americans because it strikes a balance: it keeps these lands open to the public while limiting new road construction and most large-scale logging in the last, best intact places. It safeguards the core habitat our hunting and fishing traditions depend on, the clean water our fisheries need, and the backcountry experiences that draw millions of Americans into the woods every year. Forest management and wildfire resilience are legitimate concerns, but rescinding the Roadless Rule wholesale is the wrong tool. The rule already includes exceptions for public safety and wildfire response — targeted, science-based management can happen without dismantling the protections that keep our largest roadless areas intact. We should invest in home hardening and fuels treatments in the wildland-urban interface, not treat roadless backcountry as a timber supply opened under the banner of wildfire risk. For these reasons, I ask the Forest Service to: 1.Withdraw the proposed rescission of the 2001 Roadless Area Conservation Rule and keep 36 CFR Part 294, Subpart B in effect nationwide, including on the Tongass National Forest. 2.Reject eliminating the national roadless standard in favor of piecemeal, forest-plan-level decisions. A patchwork of local decisions provides no durable protection for backcountry crossing forest and state boundaries, and would put millions of acres of public land up to local political pressure. 3.Extend the public comment period. Thirty days is far too short for a rulemaking of this magnitude, affecting tens of millions of acres and a half-century of conservation policy. The American public deserves a full and meaningful opportunity to weigh in. In closing: I have spent my life retreating to the backcountry of the West. Those days — with my family, with my friends, in the elk woods and on the trout streams — are the most important things in my life. The Roadless Rule is part of the promise that previous generations made to protect these lands for all of us. Please do not break it.