Comment Analysis · Docket FS-2025-0001

FS-2025-0001-271737

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted August 26, 2026 On Regulations.gov

In short: The comment places on the record specific data from DellaSala et al. (2011) and the Forest Service's own EIS and GRAIP to document that roadless areas provide critical drinking water infrastructure, and requests that the agency evaluate the cumulative water quality impacts and public costs of rescinding the 2001 Roadless Area Conservation Rule.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, Evidence.

Standard dismissals it defeats

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.

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.
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.
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
- “protecting roadless forests also protects one of America's most important forms of public infrastructure: clean and reliable drinking water”
- “limiting additional road construction in Inventoried Roadless Areas would reduce future risks to streams and drinking-water source areas”
- “Sediment entering streams can degrade aquatic habitat, impair drinking-water sources, and increase treatment and maintenance costs”
- “Clean water should be treated as essential public infrastructure, not simply as an environmental benefit”
Scientific Research Evidence
- “DellaSala, Karr, and Olson (2011), drawing on Forest Service watershed inventories and research”
- “The Forest Service's own Roadless Area Conservation Final Environmental Impact Statement recognized that road construction and timber harvesting can adversely affect water quality”
- “Its Geomorphic Road Analysis and Inventory Package (GRAIP) is specifically designed to identify road-related risks to streams and aquatic ecosystems”
- “Incorporate DellaSala, Karr, and Olson (2011) and the underlying Forest Service watershed research into the environmental analysis”
Economic Impact Fiscal
- “communities may face additional expenses for water treatment, watershed restoration, reservoir maintenance, and regulatory compliance”
- “These costs can ultimately fall on taxpayers and water-rate payers”
- “Quantify potential increases in drinking-water treatment, watershed restoration, reservoir maintenance, and other public costs”
- “Protecting intact watersheds is therefore a prudent investment in water security and taxpayer resources”

What it names

Works cited: 10.2489/jswc.66.3.78aDellaSala et al. 2011

The comment

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

I strongly support retaining the 2001 Roadless Area Conservation Rule because protecting roadless forests also protects one of America’s most important forms of public infrastructure: clean and reliable drinking water. National forests are major sources of water for communities across the United States. DellaSala, Karr, and Olson (2011), drawing on Forest Service watershed inventories and research, reported that national forests provide approximately 15–18% of the nation’s runoff in the contiguous United States, with roughly one-third of that runoff originating in Inventoried Roadless Areas. They estimated that more than 3,400 communities in 33 states rely on national-forest drinking water, representing at least 124 million people. This makes the Roadless Rule more than a forest-management policy. It is also a watershed-protection policy. The Forest Service’s own Roadless Area Conservation Final Environmental Impact Statement recognized that road construction and timber harvesting can adversely affect water quality. The agency identified sediment and nutrients entering streams, changes in water temperature, and other impacts associated with roads and forest management. It specifically concluded that limiting additional road construction in Inventoried Roadless Areas would reduce future risks to streams and drinking-water source areas. Roads can create long-term changes to how water moves across a landscape. Road surfaces, drainage structures, stream crossings, exposed soil, and road cuts can concentrate runoff and increase erosion. Sediment entering streams can degrade aquatic habitat, impair drinking-water sources, and increase treatment and maintenance costs for downstream communities. The Forest Service itself recognizes that roads can alter watershed hydrology and geomorphic processes and can degrade water quality. Its Geomorphic Road Analysis and Inventory Package (GRAIP) is specifically designed to identify road-related risks to streams and aquatic ecosystems. The public cost of water-quality degradation also deserves consideration. When sediment loads increase in municipal watersheds, communities may face additional expenses for water treatment, watershed restoration, reservoir maintenance, and regulatory compliance. These costs can ultimately fall on taxpayers and water-rate payers. The Forest Service should therefore evaluate the proposed rescission not simply by asking whether individual roads can be engineered to minimize erosion, but by examining the cumulative effects of expanding road networks across entire watersheds. I respectfully request that the Forest Service: 1. Fully evaluate the drinking-water importance of Inventoried Roadless Areas and the communities that depend on national-forest watersheds. 2. Incorporate DellaSala, Karr, and Olson (2011) and the underlying Forest Service watershed research into the environmental analysis. 3. Evaluate cumulative sediment, erosion, water-temperature, and hydrologic impacts associated with additional roads and forest activities. 4. Quantify potential increases in drinking-water treatment, watershed restoration, reservoir maintenance, and other public costs resulting from increased sedimentation. 5. Give particular consideration to roadless areas containing municipal drinking-water source areas and headwaters. 6. Explain why rescinding the Roadless Rule is necessary when the Forest Service’s own analysis recognizes that road construction can adversely affect water quality and that limiting new roads reduces future risks to drinking-water source areas. Clean water should be treated as essential public infrastructure, not simply as an environmental benefit. Intact forested watersheds naturally regulate runoff, stabilize soils, filter water, recharge groundwater, and support downstream aquatic ecosystems. Once roads introduce chronic erosion and sedimentation into a watershed, the resulting impacts can be difficult and expensive to reverse. Protecting intact watersheds is therefore a prudent investment in water security and taxpayer resources. The Forest Service should not eliminate protections for millions of acres without demonstrating that the expected benefits of additional road construction outweigh the documented risks to water quality and the potential costs to downstream communities. For these reasons, I urge the Forest Service to retain the 2001 Roadless Area Conservation Rule. References DellaSala, D.A., Karr, J.R., & Olson, D.M. (2011). “Roadless areas and clean water.” Journal of Soil and Water Conservation, 66(3), 78A–84A. DOI: 10.2489/jswc.66.3.78A. USDA Forest Service. Roadless Area Conservation Final Environmental Impact Statement, Volume 1 and Volume 3. USDA Forest Service. Geomorphic Road Analysis and Inventory Package (GRAIP).