Comment Analysis · Docket FS-2025-0001

FS-2025-0001-295504

Opposes rescissionA0 noneSubstance 6/24Posted September 1, 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

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

  • Environmental Protection Biodiversity
    • “Landscape Fragmentation: Roads heavily impact the broader ecosystem”
    • “Persistent Environmental Degradation: Road construction permanently alters the physical environment”
    • “rare and irreplaceable wild landscape”
    • “total absence of motorized vehicles and the absolute presence of nature”
  • Governance Policy Process
    • “administrative record supporting the 2001 Rule—developed over years of rigorous scientific analysis”
    • “proportionality of process that the current proposed rescission has failed to match”
    • “extensive public engagement”
    • “The Department should seriously consider this deficit before proceeding”
  • Recreation Tourism Public Use
    • “The public deserves the right to experience Ellicott Rock”
    • “without the intrusion of motorized noise”
    • “memories of swimming in the cold, clear river”
    • “beginning of a decade of outdoor adventures”

What it names

National Forests
Sumter National Forest

The comment

Dear Secretary Rollins and Chief Schultz: I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. As an outdoor enthusiast, I believe the administrative record supporting the 2001 Rule—developed over years of rigorous scientific analysis and extensive public engagement—represents a proportionality of process that the current proposed rescission has failed to match. The Department should seriously consider this deficit before proceeding. In particular, I request that the Department maintain protections for the Ellicott Rock roadless area in the Sumter National Forest. This area holds profound historical and geographical significance as the junction where Georgia, North Carolina, and South Carolina meet—a gathering place for people long before state borders were established. Located just two hours from my home in Greenville, South Carolina, it stands as a rare and irreplaceable wild landscape in the southeastern United States. My connection to Ellicott Rock is deeply personal. In 2016, I first visited this area with my 11-year-old son just before he joined BSA Troop 19 of Greenville. It was a magical experience defined by the total absence of motorized vehicles and the absolute presence of nature. Memories of swimming in the cold, clear river, catching and cooking crayfish, and hanging our first bear bag marked the beginning of a decade of outdoor adventures for us. Ellicott Rock is not just another busy, overrun destination crowded with gas-powered vehicles; it is a sanctuary. Rescinding the Roadless Rule would open Ellicott Rock to road construction and severe ground disturbance. A specific comment on this area is vital because the direct and indirect impacts of roads extend far beyond the asphalt or gravel surface itself: Landscape Fragmentation: Roads heavily impact the broader ecosystem. An estimated 15 to 20 percent of the contiguous United States is ecologically affected by roads due to edge effects, altered runoff patterns, and downstream disturbance (Forman & Alexander, 1998). Globally, while 80 percent of Earth's terrestrial surface remains roadless, most of that area is severely fragmented into patches smaller than one square kilometer (Ibisch et al., 2016). Persistent Environmental Degradation: Road construction permanently alters the physical environment. It compacts soil to roughly 200 times the density of undisturbed forest soil and alters at least eight major physical characteristics of the landscape. These disturbance patterns persist for decades; even logging skid trails show measurable damage 40 years after their last use (Trombulak & Frissell, 2000). The public deserves the right to experience Ellicott Rock and our nation's remaining roadless areas without the intrusion of motorized noise, soil erosion, and the siltation of pristine creeks and rivers. Because so little of our public land is set aside to preserve these roadless qualities, I urge the Department to withdraw the proposed action and allow the 2001 Roadless Area Conservation Rule to remain fully operative. Respectfully, CommentID: RLC-20260831-SF8CJY

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