Comment Analysis · Docket FS-2025-0001

FS-2025-0001-281462

Opposes rescissionA1 strongSubstance 12/24Owed an answerPosted August 28, 2026 On Regulations.gov

In short: The comment documents the specific ecological and management deficiencies of rescinding the 2001 Roadless Area Conservation Rule, citing 50,000 acres of roadless land in the Coconino National Forest and 18.2 million acres of potentially affected environment to argue that individual forest plans are insufficient substitutes for the national safeguard.

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 Evidence, 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

Wildlife Habitat
- “Roads fragment wildlife habitat”
- “large connected wildlife habitat”
- “preserve these lands for wildlife”
Water Quality Quantity
- “disturb watersheds and soils”
- “healthy watersheds”
- “preserve these lands for... watersheds”
Environmental Protection Biodiversity
- “biological diversity”
- “intact forest”
- “Roadless areas provide values that cannot always be recreated”
Recreation Tourism Public Use
- “hiking, camping, exploring, and enjoying our National Forest lands”
- “quiet recreation”
- “places that still feel genuinely wild”

What it names

National Forests: Coconino 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 strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service and USDA to reject Alternative 2 and select Alternative 1, the No Action Alternative, keeping the Roadless Rule and its protections in effect. I live in Flagstaff, Arizona, and spend a great deal of my free time hiking, camping, exploring, and enjoying our National Forest lands. These places are not abstract areas on a map to me. They are some of the places I value most. One of the things that makes them special is that there are still large areas where roads, development, noise, and fragmentation have not taken over the landscape. Once a road is built through an intact forest, the character of that land changes. Roads fragment wildlife habitat, disturb watersheds and soils, increase human access and disturbance, and create long-term maintenance obligations. A road can eventually be closed or decommissioned, but that does not mean the ecological effects of building it simply disappear. I am particularly concerned about the effects of rescission in Arizona. The Forest Service's own Roadless Area Conservation mapping identifies approximately 50,000 acres of inventoried roadless land in the Coconino National Forest in a forest-plan category that otherwise allows road construction and reconstruction. This demonstrates exactly why a consistent national protection is important. Relying entirely on individual forest plans is not equivalent to maintaining the Roadless Rule. I also do not believe wildfire risk justifies eliminating the Roadless Rule nationwide. I support responsible forest management and necessary actions to protect communities from wildfire. However, the existing Roadless Rule is not an absolute prohibition on forest management. It contains limited exceptions and allows certain vegetation treatments intended to maintain or restore ecosystem conditions, including treatments aimed at reducing the risk of uncharacteristic wildfire effects. The proposed rule itself also acknowledges an important tradeoff: greater public access can increase the potential for human-caused wildfire ignitions. It therefore does not make sense to assume that opening more intact areas to roads is automatically synonymous with improving fire safety. I am also concerned by the sheer scale of the change being considered. USDA's proposed rule states that, under current land-management plans, approximately 18.2 million acres of the potentially affected environment are lands where permanent roads could be allowed by those plans but are currently prohibited by the Roadless Rule. The proposal also states that future land-management-plan amendments could further increase areas where road construction and timber harvest are allowed. That is precisely why the national safeguard should remain in place. Roadless areas provide values that cannot always be recreated after they are lost: large connected wildlife habitat, healthy watersheds, quiet recreation, scenic landscapes, biological diversity, and places that still feel genuinely wild. Public lands should not have to be developed or made economically productive in order to justify protecting them. There may be specific situations where carefully designed management is necessary, and the existing Rule already recognizes limited exceptions. Those situations should be addressed individually rather than by eliminating protections across tens of millions of acres of National Forest land. Please reject the proposed rescission of 36 CFR Part 294, Subpart B, reject Alternative 2, and select Alternative 1, the No Action Alternative. Keep the 2001 Roadless Area Conservation Rule in effect and preserve these lands for wildlife, watersheds, recreation, and future generations. Thank you for considering my comment.