Comment Analysis · Docket FS-2025-0001

FS-2025-0001-306341

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted September 3, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to quantify sediment delivery to 7,000 municipal intakes, identify enforceable water protection provisions equivalent to 36 CFR 294.12/294.13, reconcile the addition of road mileage with admitted maintenance shortfalls, apply cited fragmentation rates to 40.1 million acres, and properly assess small business impacts, while documenting the commenter's 20-year recreational use of the White River National Forest and observed water quality degradation.

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 Analytical gap, 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

Water Quality Quantity
- “seen more sediment in the water, increased bank erosion”
- “quantify projected sediment delivery to the more than 7,000 municipal intakes”
- “24 million people use water originating within potentially affected roadless areas”
- “Lack of maintenance commonly has detrimental effects on water quality”
Recreation Tourism Public Use
- “I hike, camp, fish, rock climb, forage, ski, and ice skate”
- “seek its quiet to get away from everyday noise”
- “My future children should not inherit fewer wild places”
- “estimates at least $6.1 million/year in lost recreation benefit”
Environmental Protection Biodiversity
- “New roads also fragment habitat, increase erosion and stream sediment, spread invasives”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “add disturbance to intact places”
- “apply the cited fragmentation range to the 40.1 million acres”
Governance Policy Process
- “The agency owes the public comparable effort in return”
- “ask that the agency respond to each issue raised here”
- “analyze in the DEIS an alternative retaining the 2001 rule's protections”
- “provide a reasoned explanation on the record”

What it names

National Forests: White River National Forest
Law cited: 36 CFR 294.12

Attachments

20 files. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter
Supporting material
Supporting material
Own letter
Own letter
Supporting material
Own letter
Own letter
Own letter
Own letter
Own letter
Own letter
Own letter
Own letter
Own letter
Own letter
Own letter
Own letter
Own letter
Own letter

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 B"H The country I am writing about includes the White River National Forest. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I've recreated in the White River National Forest and surrounding areas for more than 20 years. After nearby roadwork, I've seen more sediment in the water, increased bank erosion, and muddier, less stable habitat. To name a few I hike, camp, fish, rock climb, forage, ski, and ice skate throughout this country. I also seek its quiet to get away from everyday noise, talk/pray to G-d, & think about my choices and meaning. Building more roads into undeveloped country makes little sense when the agency is already billions behind on maintaining existing roads. New roads also fragment habitat, increase erosion and stream sediment, spread invasives, and add disturbance to intact places. Millions drink water originating in these relatively unimpaired watersheds. My future children should not inherit fewer wild places than I did.I want them to know country without roads, engines, or constant development, and to have the same chance to find perspective and meaning there. The 2026 fire season reinforced this: some days the mountains vanished in smoke, the air smelled of it all day, the sun became red, and poor air quality made me think twice before going outside. I submitted comments during the previous rescission process and raised specific concerns. The agency owes the public comparable effort in return. You don't have to agree with me, but you should engage with what I actually said. I raise the following issues for the record and ask that the agency respond to each: Issue 1: Road sediment is quantified and then set aside I paddle and fish water that starts in this country; clean, free-running rivers are why I go. The DEIS says skid roads, trails, log landings, and similar timber-sale disturbances are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." Yet no projection of sediment delivery follows. I ask the agency to quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. Issue 2: Twenty-four million people's drinking water is asserted away I am downstream of decisions made in these forests. About 24 million people use water originating within potentially affected roadless areas through more than 7000 municipal intakes, and less than 12 percent of these watersheds are currently impaired. The DEIS says forest plans address public drinking-water sources without identifying one enforceable provision. I ask the agency to identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. Issue 3: Unmaintained roads damage water, by the agency's own admission I live with whatever a watershed sheds. A road nobody can afford to maintain eventually fails into the river. The agency states: "Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance." Yet the proposal would add road mileage despite a maintenance shortfall the agency identifies as a cause of water-quality damage. I ask the agency to reconcile those positions. Issue 4: Fragmentation is quantified and not applied Good fishing depends on intact, connected watersheds. The DEIS cites a finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, yet provides no projection across the 40.1 million affected acres. I ask the agency to apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. Issue 5: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and guides help people like me access them. The proposed rule certifies no significant impact on small entities while the DEIS identifies outfitters, guides, and touroperators as affected and its Cost Benefit Analysis estimates at least $6.1 million/year in lost recreation benefit. The regulatory flexibility analysis reaches its no-impact conclusion by spreading a $9 million annual expenditure loss across every small firm in the sector nationally instead of assessing permit-holding outfitters and guides in affected areas, while conceding some firms may lose receipts. I ask the agency to withdraw the certification and assess the small entities actually operating in potentially affected roadless areas. I request that the agency respond in the record to each issue raised here and analyze in the DEIS an alternative retaining the 2001 rule's protections. Where this proposal reaches factual conclusions that differ from the agency's prior findings quoted here, I ask the agency to acknowledge the change in position and provide a reasoned explanation on the record.