Comment Analysis · Docket FS-2025-0001

FS-2025-0001-292020

Opposes rescissionA0 noneSubstance 1/24Posted August 31, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 4 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

Scored with own additions — A family member whose own text beyond the shared letter was scored and combined with the letter's score.

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
    • “severely harm our drinking water”
    • “Roads are the largest controllable source of forest sediment”
    • “sediment from logging related disturbances contaminated the watershed”
    • “124 million Americans stand to face contaminated water”
  • Environmental Protection Biodiversity
    • “Destroying some of the few remaining natural areas”
    • “not yet been sullied by roads and development”
    • “serious and irreversible mistake”
    • “impact every generation to come”

The comment

Repealing the Roadless Rule will severely harm our drinking water. Roads are the largest controllable source of forest sediment as proven in Roadless areas & clean water. Journal of Soil & Water Conservation, 66(3), 78A-79A. (DellaSala, D. A. 2011) For example, Salem, OR had to spend roughly $100 million after sediment from logging related disturbances contaminated the watershed. Dominick A. DellaSala's 2011 synthesis in the Journal of Soil & Water Conservation proves that 3,400 communities across 33 states rely on national forests for drinking water, including Los Angeles, San Francisco, Denver, & California's central valley, which provides food for the entire country. Roughly 124 million Americans stand to face contaminated water if the Roadless Rule isn't in place. PROTECT OUR PUBLIC LANDS, THEY ARE FOR THE PEOPLE (NOT FOR SALE FOR THE HIGHEST BIDDING COMPANY) AND MUST BE PROTECTED FOR FUTURE GENERATIONS TO ENJOY. Thank you for your attention to this matter. JFP

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