Comment Analysis · Docket FS-2025-0001

FS-2025-0001-302554

Opposes rescissionA0 noneSubstance 1/24Posted September 2, 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. See the letter, its submissions and topics.

Carries the letter's score — A copy of a family's letter; it holds the score and answerability level of the letter it sent.

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. This rating is the one its shared letter earned.

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”

What it names

Works cited
DellaSala et al. 2011

The comment

Repealing the roadless rule will severely harm our drinking water. Roads are the largest controllable source of forest sediments as proven in roadless areas and clean water. Journal of soil and water conservation, 66(3), 78A-79A. For example Salem Oregon had to spend roughly $100 million after sediment from logging related disturbances contaminated the watershed.

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