Comment Analysis · Docket FS-2025-0001

FS-2025-0001-311354

Opposes rescissionA0 noneSubstance 2/24Posted September 3, 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

  • Water Quality Quantity
    • “pressing water supply issues”
    • “drinking water to 25 million Americans”
    • “forested lands produce high quality water”
    • “logging worsen water quality”
  • Scientific Research Evidence
    • “A 2026 study found”
    • “Olden JD, Postel SL, Dombeck MP”
    • “Dominick A. DellaSala, James R. Karr”
    • “Journal of Soil and Water Conservation”

What it names

Works cited
10.1371/journal.pwat.0000538DellaSala et al. 2011

The comment

As a Southern California resident, I am acutely aware of the pressing water supply issues that plagues much of the state I call home. Serious concerns about harm to our already vulnerable water supply is one of many, many reasons why I am wholeheartedly against repealing the Roadless Area Conservation Rule. A 2026 study found that land protected under the roadless rule provides drinking water to 25 million Americans. Here in California alone, roughly 1 in 4 residents (9.5 million individuals) rely on water sources that are within or downstream of lands protected by the roadless rule. Further, forested lands produce high quality water by moderating water temperature, lowering sediment levels, and naturally filtering out contaminants, making it less costly to treat for human consumption (1). Land development and resource extraction such as logging worsen water quality by damaging vegetation, drastically increasing the rate of erosion and sediment deposition in water sources, polluting water sources, increasing water temperature, and altering stream patterns (1, 2). Water is not an infinite resource, and if we don’t take aggressive steps to safeguard our water supply, we will eventually find the consequences to be existential. Protecting the land that provides these water sources is necessary to continue to provide clean drinking water to a large portion of the nation’s most populous state, and ultimately, for the long-term stability of our society. Citations: 1. Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, et al. (2026) Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538. https://doi.org/10.1371/journal.pwat.0000538 2. Dominick A. DellaSala, James R. Karr & David M. Olson (2011) Roadless areas and clean water, Journal of Soil and Water Conservation, 66:3, 78A-84A, DOI: 10.2489/ jswc.66.3.78A

Keep learning. Keep speaking up.The Roadless Rule depends on public engagement. Share what you've learned.

© 2026 roadless.org - Defending America's Last Wild Forests

Privacy Policy|Questions or concerns? noroads@roadless.org|Follow us: @defendroadless