Comment Analysis · Docket FS-2025-0001

FS-2025-0001-297019

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted September 1, 2026 On Regulations.gov

In short: The comment places on the record specific evidence that rescinding the Roadless Rule would expose Tracy Ridge in the Allegheny National Forest to road construction and ground disturbance, citing a 2025 Nature study on freshwater extinction risks and a 2026 Pew poll on public support to argue that the Rule is the only regulatory mechanism preventing downstream water quality degradation and habitat loss in that specific location.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Evidence.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
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.
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
- “degrade drinking-water supplies”
- “sedimentation, and stream crossings”
- “send further pollution down stream”
- “clean water are fading”
Environmental Protection Biodiversity
- “Freshwater extinction risk”
- “habitat fragmentation, and sediment loading”
- “shielded countless management decisions from triggering that consultation”
- “concentrated in the rarest, most threatened ecosystems”
Public Opinion Support
- “more than 99.8% of submitters opposed the rescission”
- “76% of likely voters support the Roadless Rule”
- “bipartisan backing from 71% of Republicans, 80% of Democrats”
- “More than 100 members of Congress have co-sponsored”
Legal Regulatory Framework
- “Section 7 of the Endangered Species Act”
- “forest plans alone, without the Roadless Rule's overlay, fail to provide adequate safeguards”
- “codify the Rule so it could not be rolled back without an act of Congress”
- “regulatory mechanism capable of sustaining that condition”

What it names

National Forests: Allegheny National Forest
Roadless areas: Tracy Ridge
Works cited: 10.1038/s41586-024-08375-z

The comment

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

Dear Secretary Rollins: Scientific training means being able to say what the evidence doesn't support, not just what it does. It doesn't support this rescission. I am an outdoors enthusiast who grew up spending time outside all the time. As I grew to love science through school I have tied it back into my love for the outdoors I can point to one morning that captures all of it. One of my major research projects regards various human made pollutants such as PFAS (or forever chemicals). In this area in particular we have seen the direct effects of various environmental contaminants from manufacturing runoff. This has included PFAS, the forests around us and the clean water are fading with more and more human involvement The landscape at the center of the preceding account exists in its present condition because the Roadless Rule has held; rescission would remove the only regulatory mechanism capable of sustaining that condition. Regarding the Tracy Ridge in the Allegheny National Forest, Pennsylvania: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. Freshwater extinction risk. Aquatic species face disproportionate extinction risk globally. A multi-taxon assessment of 23,496 freshwater species found that 24% are threatened with extinction, driven primarily by pollution, habitat fragmentation, and sediment loading from upstream disturbance (Sayer et al. 2025). — Sayer, Catherine A.; Fernando, Eresha; Jimenez, Randall R.; et al., 2025 · Nature (https://doi.org/10.1038/s41586-024-08375-z) Rescinding the Roadless Rule would open the Tracy Ridge, Allegheny National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. I have seen extensive evidence of human activities affecting downstream water. With the recent pollution from a new factory in the region killing large quantities of fish this impact is even more noticeable. I live across the street from our River yet I can not swim it, nor drink from it due to pollution down stream. Rescission of the roadless rule would prove to send further pollution down stream. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. The proposed rollback of the 2001 Roadless Rule jeopardizes nearly 58 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service, comprising around a third of the territory in our national forest system. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. Beyond the headline fights over wildfire, recreation, and water, the Roadless Rule plays a quieter but essential role in federal land law and ecological assessment. Section 7 of the Endangered Species Act requires the Forest Service to consult before any action that may affect listed species — and the rule's road-construction prohibition has shielded countless management decisions from triggering that consultation. The rule also props up federal forest planning: peer-reviewed analyses of forest plan adequacy consistently find that forest plans alone, without the Roadless Rule's overlay, fail to provide adequate safeguards for sensitive species and intact landscapes. And state-level conservation rankings (NatureServe and others) repeatedly identify roadless areas as concentrated in the rarest, most threatened ecosystems in the lower 48 — the kinds of places where a road, once built, cannot be undone. This comment joins the record in opposition to the proposed rescission action. Warm regards,