Comment Analysis · Docket FS-2025-0001

FS-2025-0001-289152

Opposes rescissionA0 noneSubstance 6/24Posted August 31, 2026 On Regulations.gov

Exact copy — Byte-identical to another submission. This comment stands for 2 submissions in its group.

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

Water Quality Quantity
- “clean water”
- “natural source-water protection zones”
- “significantly less sedimentation and runoff”
- “clean drinking water that originates in roadless watersheds”
Wildlife Habitat
- “wildlife habitat”
- “interior habitat that is critical for species”
- “fragmented landscapes cut by roads”
- “carbon storage provided by intact mature forests”
Recreation Tourism Public Use
- “outdoor recreation”
- “quiet, backcountry character”
- “hiking, hunting, and dispersed recreation economy”
- “opportunity to experience true backcountry solitude”
Environmental Protection Biodiversity
- “established conservation benchmarks”
- “last remaining undeveloped portions of our National Forest System”
- “wild character of these places is permanently lost”
- “irreplaceable public asset”

What it names

National Forests: George Washington National Forest
Roadless areas: Gum RunLittle RiverOak KnobRamseys Draft Addition

The comment

To the United States Department of Agriculture and the United States Forest Service: I am writing to formally oppose the decision to rescind the Roadless Area Conservation Rule (RACR) as it pertains to the George Washington National Forest (GWNF) and the proposed Shenandoah Mountain National Scenic Area (SMNSA), and more broadly to ALL public lands to which this Rule applies. My opposition is based on the quantifiable impacts this rule change will have on established conservation benchmarks. First, the proposed SMNSA contains five designated roadless areas—Oak Knob, Gum Run, Skidmore Fork, Little River, and Ramseys Draft Addition—totaling 70,000 acres. According to the spatial data regarding the GWNF North River District, this constitutes the largest concentration of roadless acreage in the eastern United States. Second, the stated purpose of the SMNSA initiative is to secure permanent protection for three primary benefits: clean water, outdoor recreation, and wildlife habitat. The value of roadless land to these specific benefits is well established. Roadless areas serve as natural source-water protection zones; without road construction, there is significantly less sedimentation and runoff, which maintains the high water quality required by downstream communities and aquatic ecosystems. Furthermore, large, unbroken forest blocks provide interior habitat that is critical for species that cannot thrive in fragmented landscapes cut by roads. Finally, the absence of motorized road networks preserves the quiet, backcountry character that supports the hiking, hunting, and dispersed recreation economy of the Shenandoah Valley. Rescinding the RACR directly exposes these specific acres to new road construction, logging, and other development activities, which would degrade all three of these established benefits. The factual record shows that these 70,000 acres are unique in just my area of eastern landscape due to their size and lack of road incursion. I urge the Department to maintain the Roadless Area Conservation Rule to ensure that the specific characteristics of the Shenandoah Mountain area are not degraded prior to the conclusion of the legislative process regarding the National Scenic Area designation. While the Shenandoah Mountain area serves as a specific example, my opposition to this action extends to all National Forest roadless areas across the nation that would be affected by a full rescission of the RACR. These lands represent the last remaining undeveloped portions of our National Forest System. Once roads are constructed and development occurs, the wild character of these places is permanently lost; fragmentation cannot be reversed within a human lifetime. To open these areas to new road construction is to forfeit an irreplaceable public asset in exchange for short-term extractive use that will only enrich private interests. Finally, while the opportunity to comment on the Draft Environmental Impact Statement (DEIS) is provided, the proposed action to rescind the RACR would alter the baseline management standards for these lands before the Senate Agriculture Committee has completed its deliberation on the SMNSA. The harm of this action would be borne by ALL American citizens. National Forests are public lands held in trust for the benefit of the entire nation, not just for the industries that would profit from their development. Every citizen has a stake in the clean drinking water that originates in roadless watersheds, the carbon storage provided by intact mature forests, and the opportunity to experience true backcountry solitude. Rescinding the RACR would strip current citizens of their benefits and beauty, and would deny future generations of Americans of their right to inherit wild, undeveloped public lands. I urge the Department to recognize that the Roadless Area Conservation Rule protects values that belong to all of us, and to maintain the rule in its entirety. Sincerely, A citizen of these great American lands.