Comment Analysis · Docket FS-2025-0001

FS-2025-0001-292214

Opposes rescissionA1 strongSubstance 11/24Owed an answerPosted August 31, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission of 36 CFR part 294, Subpart B, would result in $6.1 million in annual recreation and tourism losses in the White River National Forest area and ignores documented opposition from Tribal governments, thereby failing to support the ecological and cultural risks of the rule change.

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

Environmental Protection Biodiversity
- “protecting watershed integrity, drinking water sources, habitat connectivity for wildlife”
- “biodiversity of some of the last largely unfragmented forest landscapes”
- “Roads are the primary vector for the sedimentation, erosion, habitat fragmentation, and introduction of invasive species”
Recreation Tourism Public Use
- “backbone of the recreation- and tourism-based economy”
- “recreation and tourism interests could see estimated losses of $6.1 million annually”
- “operable, accessible roadless terrain”
Water Quality Quantity
- “protect the headwaters and watersheds that supply drinking water”
- “protecting watershed integrity, drinking water sources”
- “sedimentation, erosion”
Tribal Sovereignty
- “majority of Tribal governments consulted oppose this rescission”
- “threats to ecological health, sacred sites, and subsistence resources on ancestral homelands”
- “governments with the deepest and longest-standing relationship to these landscapes”

What it names

National Forests: White River National Forest
Law cited: 36 CFR part 294

The comment

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

Joshua White Acting Director, Ecosystem Management Coordination USDA Forest Service 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 Submitted electronically via https://www.regulations.gov **Re: Opposition to Proposed Rescission of the 2001 Roadless Area Conservation Rule** **Docket No. FS-2025-0001; RIN 0596-AD66** Dear Director White, I am writing to oppose the U.S. Department of Agriculture's proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR part 294, Subpart B), filed August 19, 2026. I urge the Department to withdraw this proposal and retain the existing nationwide protections for inventoried roadless areas rather than remove and reserve Subpart B as proposed. **This rulemaking directly affects the place I live.** I live in Carbondale, Colorado, in the Roaring Fork Valley, adjacent to the White River National Forest, which contains substantial inventoried roadless acreage covered by this proposal. These roadless lands are not an abstraction to my community — they are the backbone of the recreation- and tourism-based economy that supports the Roaring Fork Valley, they protect the headwaters and watersheds that supply drinking water to downstream communities including my own, and they buffer the wildland-urban interface where my neighbors and I live. The Department's own cost-benefit analysis acknowledges that recreation and tourism interests could see estimated losses of $6.1 million annually as a result of this rule change, concentrated in exactly the kind of operable, accessible roadless terrain found in forests like the White River. That is a direct cost to communities like mine, weighed against a proposal the Department itself describes as producing only "modest and localized" management benefits. **The proposed rescission trades a durable, science-based protection for an uncertain patchwork of local outcomes.** The 2001 Rule has provided 58.5 million acres of inventoried roadless areas with a consistent baseline of ecological protection for nearly a quarter-century — protecting watershed integrity, drinking water sources, habitat connectivity for wildlife (including federally listed threatened and endangered species), and the biodiversity of some of the last largely unfragmented forest landscapes in the National Forest System. Roads are the primary vector for the sedimentation, erosion, habitat fragmentation, and introduction of invasive species that most directly degrade these values. Shifting responsibility for these protections to individual forest-level land management plans, as described in the "Rationale for the Proposal" section of the notice, does not eliminate that risk — it simply disperses the decision across more than a hundred separate planning processes with varying levels of scrutiny, funding, and public engagement, while removing the uniform floor that has kept roadless-area outcomes predictable and defensible for 25 years. **The Department's own record undercuts the case for rescission.** The notice's own "Tribal Input Received" section documents that the majority of Tribal governments consulted oppose this rescission, citing threats to ecological health, sacred sites, and subsistence resources on ancestral homelands, and specifically requesting retention of the current rule or a strengthened, co-managed alternative. That opposition, from the governments with the deepest and longest-standing relationship to these landscapes, deserves far more weight than this proposal gives it. Combined with the modest and speculative economic upside cited elsewhere in the notice (an estimated 5–10 percent increase in National Forest sawtimber harvest, contingent on operability, budget, and market conditions that the Department itself calls unlikely to be fully realized), the record does not support that the benefits of rescission outweigh the ecological and cultural risks. For these reasons, I respectfully request that USDA withdraw the proposed rescission of 36 CFR part 294, Subpart B, and retain the 2001 Roadless Area Conservation Rule's national protections in full. Thank you for considering my comment.