Comment Analysis · Docket FS-2025-0001

FS-2025-0001-283550

Opposes rescissionA1 strongSubstance 6/24Owed an answerPosted August 28, 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

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

  • Wildlife Habitat
    • “wildlife segmentation”
    • “impact on wildlife habitat segmentation and disruption”
    • “incremental impact that adding new access has on wildlife”
  • Environmental Protection Biodiversity
    • “impact on the environment”
    • “combined impact of new roads in conjunction with the impact to the environment”
    • “more than a modest impact”

What it names

Law cited
36 CFR Parts 212

The comment

It is not reasonable to assume, as the Department does here, that recession of the rule will have only a "modest" impact on the environment due to the likelihood that new roads will only result in around .5 mile distance from existing roads. The Department has failed to consider the incremental impact that adding new access has on wildlife segmentation. In addition, one half-mile of road surface added over the entire breath of the landscape that the roadless rule covers, has not been considered. Similarly, the combined impact of new roads in conjunction with the impact to the environment created by the Department's new "access management regulations"(see 36 CFR Parts 212 and 261) which presume motorized access is allowed unless otherwise prohibited has not been considered. Again, the incremental impact of presuming motorized access, combined with the addition of new roads for additional access to existing roads creates impacts that the Department has not considered. That is, even new roads less that .5 mile from existing roads will have more than a modest impact on wildlife habitat segmentation and disruption in conjunction with the Department's concurrent new rule to presume access to new roads. I am a hunter, hiker and climber in Washington State and I oppose recession of the roadless rule.

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