Comment Analysis · Docket FS-2025-0001

FS-2025-0001-269801

Opposes rescissionA0 noneSubstance 6/24Posted August 25, 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

  • Recreation Tourism Public Use
    • “avid public land hunter, angler, canoeist, hiker and camper”
    • “best outdoor recreation opportunities in the state”
    • “visited each of Michigan's six Roadless Areas”
  • Wildlife Habitat
    • “provide wildlife habitat for grouse, deer, martens, woodcock, trout”
    • “top-notch upland bird habitat”
    • “lose their unique wilderness characteristics”
  • Water Quality Quantity
    • “filter headwater streams that flow into the Great Lakes”
    • “provide drinking water for 40 million people”
    • “fished the cool waters of the Big Sable”
  • Forest Management Wildfire
    • “fewer than 1% of wildfires... since 2001 have started in Roadless Areas”
    • “Roadless Rule as written allows for management for fire”
    • “roads that bring in many of the root causes of wildfires”

What it names

National Forests
Hiawatha National ForestHuron-Manistee National ForestOttawa National Forest
Roadless areas
Bear SwampGovernment Island

The comment

Dear Chief Schultz, Please uphold the multiple use principles that have guided the US Forest Service for decades and listen to the outdoorsmen and women of America by choosing NOT TO RESCIND THE ROADLESS RULE in its present form. As an avid public land hunter, angler, canoeist, hiker and camper who has visited each of Michigan’s six Roadless Areas, I am intimately aware of the immense value of these special places. I’ve fished the cool waters of the Big Sable as it flows through the Huron-Manistee National Forest’s Bear Swamp Roadless Area, I’ve paddled the emerald shores of the Hiawatha National Forest’s Government Island Roadless Area, I’ve scouted the top-notch upland bird habitat of the Ottawa National Forest’s Norwich Roadless Area, and much more. These forests offer some of the best outdoor recreation opportunities in the state. They provide wildlife habitat for grouse, deer, martens, woodcock, trout, and so much more. They filter headwater streams that flow into the Great Lakes, which hold 20% of the world’s surface freshwater and provide drinking water for 40 million people. Here in Michigan, our public lands define the scenic character of our state. If we lose these forests, we lose part of our heritage as Michiganders. Research shows that fewer than 1% of wildfires, and none of the costliest fires, since 2001 have started in Roadless Areas. Indeed, it is roads that bring in many of the root causes of wildfires like dragging chains and cigarettes. As you know, the Roadless Rule as written allows for management for fire. Instead, once these areas become roaded, they lose their unique wilderness characteristics that are so hard to come by. We would lose a wildness that in many ways defines our American spirit and our connection to the land. For all of these reasons. Please keep the Roadless Rule in place as it is. Thank you very much, Calvin Floyd

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