Comment Analysis · Docket FS-2025-0001

FS-2025-0001-260536

Opposes rescissionA0 noneSubstance 6/24Posted August 23, 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

  • Environmental Protection Biodiversity
    • “degrade habitat quality”
    • “direct and indirect effects of that activity”
    • “soil erosion to cleaner air”
    • “Direct habitat conversion and indirect fragmentation”
  • Water Quality Quantity
    • “kept the small streams small streams”
    • “Roads change them”
    • “soil erosion”
  • Scientific Research Evidence
    • “not supported by science”
    • “I am a professional ecologist”
    • “Caliskan 2013”
    • “listen to evidence and experts”

What it names

National Forests
Coronado National Forest
Roadless areas
Lower Romero WSR
Works cited
10.1186/1735-2746-10-23

The comment

Dear Mr. Schultz, As an angler, the rule has kept the small streams small streams. Roads change them. Don't open the door. Regarding the Lower Romero WSR in the Coronado National Forest, Arizona: Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Rescinding the Roadless Rule would open the Lower Romero WSR, Coronado National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. I am a professional ecologist and hold an advanced degree in ecology. Neither myself nor any colleague of mine with an environmental background supports recession of the roadless rule. Acting like this is for the benefit of fire safety is laughable and not supported by science. The benefits gained from this rule since its inception are immense. The roadless rule helps with so many facets of the environment, from soil erosion to cleaner air. Those that support this rescission are those that would benefit financially or politically at the expense of the rest of the American public and the environment. The roadless rule has bipartisan support from many user groups, from tree hugging conservationists to red blooded meat eating hunters. The stewardship of our natural resources is an essential component of what our federal government should provide. Like so many decisions in recent history across many disciplines, experts watch in dismay as the federal government subverts the will of the American public and actively acts against their best interest to please their corporate overlords. Where is your responsibility to your countrymen? To your planet? Where is your honor? Every day is exhausting and depressing for anyone who works in fields that are connected to the environment, from guides, to hotshot firefighters, to ecological researchers. Your duty is to listen to evidence and experts and to heed the will of the people. the rescission of the roadless rule checks neither of those boxes and makes the USA poorer, weaker and uglier. Forest road construction damages adjacent trees. Road construction on steep mountain terrain damages 21 to 33 percent of trees in the construction zone, depending on equipment used; on very steep terrain, damage rises to 27 to 44 percent. Direct habitat conversion and indirect fragmentation extend well beyond the road's physical footprint (Caliskan 2013). — Erhan Caliskan, 2013 · Iranian Journal of Environmental Health Science & Engineering (https://doi.org/10.1186/1735-2746-10-23) The Department is asked to close this proceeding without disturbing the Rule. With hope, CommentID: RLC-20260823-18J2BR

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